Proposed Law To Reform Face-To-Face Requirement

Proposed legislation would improve Centers for Medicare and Medicaid Services’ approach to collecting evidence regarding the eligibility of patients for home health services.

“The existing home health face-to-face requirement is simple in theory, but has proven unworkable in practice,” said Sen. Robert Menendez (D-N.J.) in a statement. “This legislation provides a straightforward process that ensures CMS works with physicians, home health agencies, and beneficiaries to devise a simple to use form that satisfies the existing face-to-face requirement.”

Menendez is one of the sponsors of the bill, “Home Health Documentation and Program Improvement Act of 2015.”


“Currently, home health agencies are often denied payment due to poorly designed and frequently misunderstood Medicare documentation requirements,” said the Visiting Nurse Associations of America (VNAA). “The legislation provides relief from past claims denials and improves the approach used by CMS to collect evidence regarding the eligibility of patients for home health services.”

The face-to-face requirement “endangers access to care for the most vulnerable patient population in the Medicare program,” VNAA said.

Homebound seniors who depend on Medicare home health services are older, poorer, sicker, and more likely to be female, disabled, and a member of an ethnic or racial minority population than all other Medicare beneficiaries combined, said Eric Berger, CEO of the Partnership for Quality Home Healthcare, citing recent data.


“The face-to-face requirement has increased the administrative burden and erected a barrier for patients in need of home health care,” said Teresa Lee, executive director of the Alliance for Home Health Quality and Innovation.

In April, CMS issued updates to clarify the home health face-to-face rule, which went into effect May 11. The new bipartisan legislation would require that CMS develop – in consultation with stakeholders – a standardized form to collect evidence that a beneficiary is eligible for home health services, in addition to other changes.

Written by Cassandra Dowell

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