Face-to-Face Rule Burdensome to Home Health Agencies

New government rules meant to prevent inappropriate reimbursements are proving burdensome to many home health agencies who worry it will interfere with their ability to provide care to those who need it. 

“The cost of caring for homebound patients is rising, and the government is trying to get a better grip on spending by requiring doctors to certify — with face to face examinations — Medicare beneficiaries’ eligibility for home health services, including intermittent skilled nursing care, physical therapy, speech therapy and part-time home health aide services,” writes Kaiser Health News.

Home health agencies billed Medicare $19.5 billion for services rendered in 2010.


But Medicare made about $2 billion of “inappropriate” payments for home health services in 2011 and 2012 because providers weren’t adequately complying with the “face-to-face” rule, according to a recent report by the Department of Health and Human Services Office of the Inspector General. 

The problem, some home health providers say, is the difficulty in following a rule they believe is vague.

“It does create delays in care, we can’t afford to go out without a face-to-face [certification] in hand and I don’t have leverage to get it done if I’m already seeing the patient,” Beatriz Lamb, regional director of a home health company, told Kaiser Health News. Her company, Franciscan St. Elizabeth Health in Indiana, cares for around 120 patients and works with around 80 doctors—translating to a lot of documentation. 


For home health reimbursement claims requiring face-to-face certification, 32% didn’t meet the CMS standards for doctors’ documentation and thus should not have been paid, according to the OIG. This sparks fear among home health companies that CMS will try to recover those “inappropriate” payments. 

But incomplete paperwork doesn’t necessarily point to fraudulent activity, Lamb told Kaiser Health News.

“The fact that you can’t get the narrative doesn’t mean that person shouldn’t get the care,” she said. 

While following the CMS requirement may take extra time, it’s worth it for physicians to keep up with paperwork even though they’re not paid to certify face-to-face encounters, according to Kent Moore, a senior strategist for physician payment at the American Academy of Family Physicians. 

“Following these documentation requirements may determine if that home health agency remains willing to work with you,” he said in the article. “Following the directions may ultimately help you and your patients.” 

Read more at Kaiser Health News. 

Written by Alyssa Gerace