Face-to-Face Visit: Beginning January 1, 2011

Medicare Program; Home Health Prospective Payment System Rate Update for Calendar Year 2011; Changes in Certification Requirements for Home Health Agencies and Hospices. Highlights in the final rule are as follows:

  • A hospice physician, hospice Nurse Practitioner, or resident/ fellow physician rotating through the hospice may perform the face to face encounter.
  • CMS clarified that the face-to-face encounter is based on benefit periods and not on actual days of care.
  • Visit Timeframe is now 30 days:  CMS has expanded the time frame for face-to-face encounters to 30 days prior to the start of the 180th-day recertification, and each subsequent recertification.
  • CMS has changed the language in 418.22 (C)(4) from “must visit” to “have a face-to-face encounter” in order to make clear that the hospice has flexibility for the practitioner to see the patient – either at the patient’s home or by the patient coming to see the physician or NP.

Clarification that the face-to-face encounter is NOT billable.  The billing regulations for hospice do not allow for physician reimbursement for administrative activities of physicians.

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