Florida Nurse Practitioner Network
Empowering Florida Nurse Practitioners as Leaders in Healthcare (Est 2002)

New Medicare Rule: Face to Face Encounter

Posted over 8 years ago by Jean Aertker

4/5/11 New CMS Home Health Care Requirement for Physicians:

Face to Face Encounter We are contacting you to inform you of a new requirement that will affect physicians that order, and the patients that they refer, for Medicare home health services. In accord with the Patient Protection Affordable Care Act, CMS issued a Final Regulation that goes into effect April 1, 2011 (first published January 1, 2011) whereby Medicare will pay for home health services only when a patient has had a face-to-face encounter with the physician that certifies the home health plan of care in the 90 days prior to, or 30 days of, the start of services. The primary reason for home health services must be addressed during this encounter.

Physicians that work in collaboration with a nurse practitioner or a clinical nurse specialist, or supervise a physician’s assistant, the face-to-face encounter may be carried out by that non-physician practitioner who must have documented their clinical findings and communicated those finding to you. However, only a physician may order home health services, certify that a face-to-face encounter occurred, and certify that other eligibility criteria are met (medical necessity and homebound status)



Margaret L. Ramstad over 8 years ago

Hospice is under a similar regulation, and requiring recurring 60 day encounters to again assess and communicate hospice eligibilty to the certifying MD. Unfortunately, there appears to have been some miscommunication or misunderstanding between some NP's and hospice companies based on conversations I've had and emails I've recieved. The miscommunication is that the NP is now able to "certify". CMS is very clear that the NP provides an attested face-to-face encounter reporting clincial findings of the patients end stage disease and progressive decline. This information is communicated to the 'certifying MD' who then attests the NP's FTFE was reviewed a used to determine recertification. CMS is also very clear that these visits are completed by an NP - not a CNS or PA. The logic fails.

The greatest loss for us, MD's and Home care / Hospice agencies is that CMS is viewing these visits as "administrative" and there is no financial reimbursement for these visits. We are expected to use our knowledge and clinical judgement and time yet not be reimbursed. There are ongoing discussions to get CMS to amend the reimbursement issue, but for now, this is what we have.

Meg Ramstad MSN ARNP-C
Halifax Health Hospice of Volusia Flagler

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