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Repeal or Reform the Physician Face-to-Face Encounter Requirement for Home Health

As a condition of payment for Medicare home health coverage, Section 6407 of the Affordable Care Act of 2010 (ACA) establishes that a patient must have a face-to-face (F2F) encounter with the physician who certifies the need for home health services. The encounter also can be provided by certain non-physician practitioners, such as physician assistants and nurse practitioners, and it must occur no more than 90 days prior to the home health start-of-care date or within 30 days after the start of care. However, when a non-physician practitioner provides the encounter, the patient’s physician must still certify that the encounter occurred and compose documentation detailing the finding from the encounter in addition to any documentation produced by the non-physician practitioner.

While we support the intention behind Section 6407 – which was to increase the need for direct encounters between patients and physicians – we are perplexed as to why the U.S. Centers for Medicare and Medicaid Services (CMS) chose to implement this rule using arcane documentation methods.