Home Health F2F Documentation Requirement Update

Posted on Thursday, October 8, 2015 2:29 PM

NAHC is continuing its efforts to advance legislation in Congress to reform the Medicare home health face-to-face (F2F) documentation requirement. Both the U.S. House and Senate are pursuing bicameral, bipartisan legislation that reforms the F2F requirement in order to address the burdensome paperwork requirements and the problems that have resulted for Medicare providers and beneficiaries. NAHC is working with Congress to support the advancement of legislation that will refine bills so that they adequately address the paperwork burdens and the problems that have resulted, including wrongfully denied claims. Lawmakers intend to coordinate their legislation efforts in order to ensure they are bicameral, as well as bipartisan. NAHC has stated that full-scale reform should:

  • Limit the physician documentation requirement to demonstrating that a timely encounter occurred, consistent with the original intent;
  • Narrow the circumstances where a face-to-face encounter is required by excluding patients transferred from a hospital or skilled nursing facility where physician encounters are virtually guaranteed;
  • Address the thousands of past claim denials by requiring the Centers for Medicare & Medicaid Services to either reach a settlement with affected home health agencies or reopen and pay those claims denied related to the physician narrative;
  • Provide an exception in areas where physicians are scarce;
  • Permit a waiver in a case-specific situation where a face-to-face encounter is not feasible; and
  • Permit face-to-face encounters by way of an expanded telehealth definition as the standard in the current law is useless as a patient must leave her home to have a telehealth visit with a physician

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