CMS Reverses Face-to-Face Policy for Home Health Care Services

The Centers for Medicare & Medicaid Services (CMS) today told the National Association for Home Care & Hospice (NAHC) that it is reversing its previous position on the face-to-face requirement for Medicare Advantage (MA) plan members who receive home health care services.

In a memorandum issued by CMS on Wednesday, the agency clarified that a Medicare Advantage Organization’s (MAO) authorization for home health services may substitute for the original Medicare face-to-face certification requirement.

“In certain circumstances, MAOs are not required to follow Original Medicare documentation requirements for the provision of Medicare covered services, but may substitute methods they deem appropriate for ensuring that the services provided are medically necessary, so long as they are not more restrictive than the coverage standards that apply in Original Medicare,” CMS stated in the memo.


The memo corrects a previous “final call” letter for 2015 rates for MA plans, in which CMS originally clarified that the plans would apply the same certification requirements as fee-for-service (FFS) Medicare to those plan members who receive home health care services.

Additionally, this directive would also require that the plans apply the face-to-face requirement—an area of serious concern for NAHC.

“NAHC questioned the rationale behind the requirement, given that MA plans have a preauthorization process that would negate the need to follow Medicare FFS certification requirements,” the trade group said in a statement.


The group also expressed its interpretation of the regulations to require that MA plans offer the same scope of benefits to their members, as Medicare does, but need not apply the same certification criteria as Medicare.

The CMS reversal arrives amid a recent lawsuit NAHC filed against the federal agency last week, claiming CMS violated Medicare laws when it retroactively denied a number of patient claims for payment under Medicare under the physician face-to-face encounter documentation requirements.

NAHC could not be reached for comment as of press time.

Written by Jason Oliva

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