CMS Issues Final Rule on Medicaid Face-to-Face Requirement

The Centers for Medicare & Medicaid Services (CMS) has issued its final rule requiring that physicians conduct and record face-to-face visits with patients in order to receive Medicaid coverage for home health services and medical equipment, similar to regulations already in place for Medicare.

CMS released the rule Wednesday in the Federal Register. It will be officially published Feb. 2 and go into effect July 1.

Under the rule, physicians must document a meeting with a person to order home health services. The encounter must relate to the patient’s need for home health services, and it must take place no more than 90 days before or 30 days after the start of services.


The rule also mandates that for certain medical equipment to be ordered and deployed, a face-to-face visit must occur and be recorded no more than six months before the start of services.

“The face-to-face encounter for home health and medical equipment may be performed by the physician or certain authorized NPPS,” the rule states. “The final rule maintains the role of the physician in ordering Medicaid home health services and equipment.”

Given that the requirement could strap agencies with certain financial obligations, CMS has provided some time before compliance is mandatory.


“Based on public comments, we recognize that there may be operational and budgetary implications with this rule and that states and providers may need time to implement this provision,” the rule states. “To ensure that states and providers are implementing the rule appropriately, we are delaying compliance with this rule for up to one year if legislature has met in that year, otherwise two years.”

CMS already published a rule for Medicare that acts similarly to the new Medicaid rule. However, unlike the Medicare rule, the Medicaid requirement qualifies telehealth as an eligible face-to-face encounter.

Written by Kourtney Liepelt

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