Updates to Medicare Manual Clarify Home Health Face-to-Face Rule

Home health agencies now can refer to an updated version of the Medicare manual that clarifies requirements for physician certification and recertification of patient eligibility for services, including changes to the face-to-face encounter requirement. 

The Centers for Medicare & Medicaid Services recently released the manual updates and a memorandum summarizing them. The changes reflect policies first described in the calendar year 2015 Home Health Prospective Payment System Final Rule published in November 2014.

A number of the manual changes relate the face-to-face rule enacted as part of the Affordable Care Act, under which a certified physician or other allowed clinician must have an in-person encounter with a beneficiary before certifying that person’s eligibility for home health care. 


The “narrative requirement” has been eliminated, although the physician still is required to attest that the face-to-face encounter occurred. The face-to-face encounter is required for certifications but not initial episodes, the manual update clarifies. It also addresses how home health agency claims denials affect the corresponding physician claim for certifying/re-certifying home health eligibility.

Home health agencies also will no longer have to count therapy visits as scrupulously, CMS stated in its memorandum about the manual updates. This is because the required 13th and 19th visit therapy reassessments have been eliminated, in favor of a qualified therapist reassessing the patient at least every 30 days.

The manual changes have an effective date of May 11.


Earlier this month, CMS updated the Medicare Benefit Policy Manual to reflect hospice regulatory changes first introduced in the 2015 payment rule. However, the update also included a new requirement that could be difficult for hospices to comply with, the National Association for Home Care & Hospice stated in news release earlier this week.

“CMS has included a new requirement that — as part of the information identifying the attending physician on the election statement — the hospice must include the physician’s national provider identifier (NPI) number,” NAHC stated in the release. “The [association] has concerns that hospices may not have access to the NPI of the attending physician at the time the election statement is signed and that patients may have some concerns about signing a form with empty spaces on it.”

One potential workaround is to include the NPI in a “For Office Use Only” box on the election statement that patients sign, and NAHC said it has contacted CMS about this option. The association also inquired about adding the NPI after the form has been signed. 

Written by Tim Mullaney

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