In the Courts: U.S. District Court Upholds Home Health Face-to-Face Narrative Requirement

December 18, 2015 | Aging Services Risk, Quality, & Safety Guidance

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The U.S. District Court for the District of Columbia has upheld a former U.S. Department of Health and Human Services (HHS) regulation requiring physicians to write a narrative in order to document that a face-to-face encounter occurred to qualify the patient for Medicare reimbursement for home health services.

Before 2010, physicians needed simply to certify that a patient required home health services. However, the Patient Protection and Affordable Care Act (PPACA) added a provision requiring physicians to document that they had a face-to-face encounter with the patient, within a timeframe to be determined by HHS, before making such a certification. In 2011, HHS revised its regulation, specifying the timeframe and requiring a written explanation regarding "why the clinical findings of such encounter support that the patient is homebound and in need" of home health services. (HHS has since eliminated the narrative requirement—see the November 7, 2014, Issues in Continuing Care Risk Management—but the agency still requires it for claims filed before the change. ...

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