CMS Clarifies: Face-to-Face Physician Requirement applies to Hospices only

Hospices are on the brink of getting more medical review under health care reform package.

The new health care reform package is throwing a lot of new requirements at home care providers, and the consequence can sometimes result in confusion.

For instance, the CMS will be issuing in the forthcoming home health agency prospective payment system a new requirement that a physician see a patient face to face before certifying her. But even though it’s in the HHA rule, the requirement will apply to hospice patients only, CMS clarified sin the April 14 Open Door Forum for home care providers.

That’s a big relief for home health agencies that thought the face-to-face requirement in the Patient Protection and Affordable Care Act (PPACA) would apply to them. However it still places a heavy regulatory burden on hospices.

For services on and after Jan. 1, 2011, under PPACA, a physician or nurse practioner must have a face-to-face encounter with hospice patients to find out their continued eligibility, explained CMS’s Randy Throndset. This requirement applies to recertifications at 180 days and each following recert.

Throndset added that physician or NP must also attest that such a visit took place.

The legislation adds, hospices with a large ratio of long-staying patients will have their care medically reviewed.

This hospice provision will most probably go into the home health agency proposed rule as there isn’t time for a hospice payment proposed rule before 2011 rates must go into effect in October, explained Throndset.

Watch out: Home care providers can anticipate information about more PPACA-related provisions coming out. “There were a number of provisions in the (PPACA legislation) that affected home care and hospice,” noted Throndset. “We’re presently analyzing many of these provisions to figure out the specifics with regards to how the provisions will finally be implemented.”

CMS will issue a proposed rule for new requirements in many cases. This means home health agencies can anticipate the 2011 PPS proposed rule to be a doozy this year, predict observers. At the moment, CMS is predicting to issue that rule this August, but that date is subject to change.

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