CMS Proposes Revisions to Face-to-Face Payment Claims

In response to growing pressure from health care organizations to revise its face-to-face encounter regulations, the Centers for Medicare & Medicaid Services (CMS) proposed changes Tuesday that would eliminate the narrative requirement in 2015.

The proposed changes come on the heels of a lawsuit filed by the National Association for Home Care & Hospice (NAHC), which argued that CMS denied payment of claims not because physicians had failed to see patients or certify them for payment, but because they did not supply sufficient paperwork.

The narrative component of face-to-face encounters mandates that doctors must explain the clinical findings of the encounter to support that the patient is homebound and in need of skilled services.


Many home health care providers argue this requirement leads to more CMS denials.

NAHC has said it is pleased with CMS’ proposed changes.

“We are delighted that CMS has heard and acted upon our recommendations,” says NAHC President Val J. Halamandaris, in a news release. “NAHC will continue fighting for the industry to get relief for past claims denied.”


NAHC represents 33,000 home care and hospice organizations, and advocates for more than 2 million home health care professionals.

Physicians will still need to certify that a face-to-face patient encounter occurred and document the date of the encounter as part of the certification of eligibility, CMS says, adding that other proposed changes to face-to-face encounter regulations include consideration only for medical records from the patient’s certifying physician or discharging facility in determining initial eligibility for the Medicare home health benefit.

Certification/re-certification of eligibility for home health services — not the face-to-face encounter visit — would be considered a non-covered service if the HHA claim was non-covered because the patient was ineligible for the home health benefit.

CMS’ proposed rule changes will “foster greater efficiency, flexibility, payment accuracy, and improved quality,” CMS says in a separate news release.

Written by Cassandra Dowell

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