VNAA - Visiting Nurse Associations of America

Face-to-Face (F2F) Physician Encounters

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Background on F2F Home Health Provision
In the final rule, CMS extend the period of time in which the F2F encounter could occur to 90 days prior to, or 30 days after, the start of home health services. A physician must document that the physician or an applicable non-physician practitioner has had a F2F encounter with the patient and the date of that encounter. The physician must also document how the patient's clinical condition supports a homebound status and the need for skilled services. The documentation must be a separate and distinct section of, or an addendum to, the certification.

PRESS RELEASE: VNAA Disappointed with CMS Decision and Pledges to Continue Improving Face-to-Face Requirements - March 31, 2011
Jonathan Blum, Center for Medicare Management Director, notified the VNAA and other national organizations via phone on March 31 that CMS will stick with full enforcement of the F2F encounter provision effective April 1. During the call to Kathleen Sheehan, VP of Public Policy for the VNAA, Blum said that CMS felt it was time to move forward with full implementation and that it would carefully monitor any problems that patients might face with access. While the F2F provision was put into effect on January 1, 2011, a grace period of 90 days had been granted by CMS before financial penalties for noncompliance would be levied. Continue Reading the Press Release from VNAA...

Face-to-Face Encounter Requirements Webinar - Mon., March 21, 2011 - FREE
On March 21, from 2:00 - 3:00 p.m. EST, the VNAA, in conjunction with BKD Health Care Group, will host a Webinar on the new Medicare F2F encounter requirements. Aaron Little, a certified public accountant at BKD, LLP, will present a complimentary Webinar about what VNAA members need to know regarding the home health and hospice physician F2F regulation. Below is a handout for the Webinar which includes: basic information on the F2F encounter requirements, exceptions to the encounter requirements, sample documentation forms for home health agencies and hospice use, updated information from the latest CMS Q&As;, and other useful tools to help ensure your agency is in full compliance with the new regulations.

CMS Releases Q&A Document on Face-To-Face Encounters: - March 16, 2011
The Center for Medicare and Medicaid Services (CMS) has been responding to questions raised by VNAA members and other providers about the new F2F requirements for home health and hospice. VNAA staff has compiled the questions that have been answered as of March 16, 2011, and will continue to update this site periodically as new questions and answers are provided.
   Updated Q&A; document as of March 16, 2011 (PDF)
   Read the Q&A; document as of February 3, 2011 (PDF)
You can always access the most updated CMS Q&A; at

Face-to-Face Coalition Letter to Jonathan Blum - March 12, 2011
The VNAA was instrumental in organizing a coalition of beneficiary groups, home health providers, physician groups, case-managers, hospitals and hospitalists who joined efforts in advocating to CMS about the F2F encounter requirements. Read the letter sent to CMS Deputy Administrator and Director of the Center for Medicare Jonathan Blum.
   Download the letter sent to Jonathan Blum

CMS Update to Hospice Medicare Manual including New Policy on F2F Encounters in Exceptional Circumstances - March 2, 2011
On March 2, 2011, CMS issued formal manual guidance that included responses to issues raised by VNAA and others on the hospice F2F encounter requirements. The Medicare Benefit Policy Manual, Pub 100-02 Chapter 9 was also revised to incorporate other existing hospice policy in addition to the new F2F encounter requirements that were mandated by the Affordable Care Act.
   Download the VNAA Summary on the Updated Hospice Medicare Manual

CMS Update to the Home Health Medicare Benefit Policy Manual, Pub 100-02 Chapter 7 - Feb. 16, 2011
On Feb. 16, 2011, CMS issued an updated on Chapter 7. Revisions included the new face-to-face encounter requirements that were mandated by the Affordable Care Act. Download the below document from VNAA, which explains what VNAA learned from CMS about the "implementation date" and the new F2F clarifications outlined in the Medicare Manual.
   Download VNAA Summary
   View the Medicare Manual

Elizabeth Hogue Webinar - Feb. 11, 2011
On Feb. 2, 2011, the VNAA hosted a conference call with Elizabeth Hogue on the new F2F requirements. Elizabeth is a private practice attorney with extensive experience in healthcare law and policy. Elizabeth discussed important issues surrounding F2F encounters on the call, such as providers potential liability if they terminate patient care, the proper use of Medical Directors and consulting physicians, and the Stark rules and exceptions. The VNAA has posted Elizabeth's articles and handouts from the conference call for your organization to use as a tool.
   View Elizabeth's Handout on Provider Liability for Abandonment - (members only)
   View FAQs about Use of Medical Directors for F2F - (members only)
   View Elizabeth's Handout on Medical Directors and the Stark Rule - (members only)

CMS Letter to Key Congressional Staff - Dec. 23, 2010
After the call with VNAA, CMS sent a memo to key Congressional staff on Dec. 23, noting that due to concerns that providers may need additional time to establish operational protocols to comply with F2F encounter requirements, "the CMS will expect full compliance with the requirements, beginning with the second quarter of CY 2011."
  Read the CMS Letter (word doc)

American Medical Association (AMA) Letter to CMS - Dec. 23, 2010
In a Dec. 23, 2010, letter to CMS Administrator, Donald Berwick, MD, the American Medical Association (AMA) strongly urged CMS to postpone by six months the enforcement of the F2F encounter for home health.
  Read the AMA Letter (pdf)

VNAA Letter Sent to CMS - Dec. 11, 2010
On Fri., Dec. 11, 2010, Andy Carter, President and CEO of VNAA, sent the below letter to CMS. This letter is just one part of VNAA's concerted effort to address nonprofit concerns on the F2F physician encounter for home health and hospice with the Centers for Medicare and Medicaid Services and Congress. Other components include mobilizing the grassroots efforts of our members and the expertise of our lobbying team. VNAA is working closely with others to present a unified message and is reaching out to national organizations beyond home health and hospice to leverage their support.
Read VNAA's Letter to CMS...
  Download the Full Letter (pdf)

Sample and Examples from VNAA Members

Samples from The Home Care Association of New Hampshire - added March 7, 2011
They developed a set of F2F encounter materials, including a physician attestation form and physician documentation guide, that will be used throughout the state. These documents were developed through a consensus process, and were agreed upon by hospitals, doctors and group medical practices in New Hampshire.
  Physician Attestation of F2F Encounter for Home Health Referral Form (doc)
  F2F Encounter Fact Sheet (doc)
  Physician F2F Encounter Guide (doc)

Samples from The Home Care Association of NJ:
The Home Care Association of New Jersey, Inc., has given VNAA permission to share some of their tools that they have developed to educate staff, referral sources and patients about the new home health F2F encounter requirement. You can find these tools below. They are in the process of developing similar tools for hospice providers.
  Physician F2F Encounter Documentation Guide (doc)
  Physician F2F Encounter Guide (doc)
  Sample "Dear Name of Hospital Discharge Planner/Social Worker" Letter (doc)
  Sample Letter for Patient (doc)

Example Forms for F2F Encounters - January 5, 2011
In light of the recent changes in Medicare, VNAA Member agencies have been quick to share F2F encounters with the membership. Below are six documents that may be of use to your organization during this transition period. These forms, shared by the Visiting Nurse Association of Kansas City, Mo., and Visiting Nurse Association Community Healthcare in Guilford, Conn., are designed to help make a smooth shift into this new process. These forms include:
  F2F Encounter Overview (pdf)
  F2F Encounter Example Documentation Form 1 (doc)
  Sample Letter to Physicians (doc)
  Letter to Patients Describing their Responsibilities Under the New Rules (doc)
  Educational Handout on F2F Encounters for Patients (doc)
  Patient Referral Fax Form (doc)

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