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Legislative Updates

CMS Clarifies Face-to-Face Requirements, Accepts Form 485


Posted on: 12/9/2011

Yesterday, the Centers for Medicare & Medicaid Services (CMS) released a statement regarding the Face-to-Face documentation requirements for home health agency (HHA) services. The agency states that it has come to their attention that some CMS contractors are denying payment for patients who use home health services following an acute or post-acute stay when:

  • The HHA uses a single form (i.e., 485) for the plan of care and the certification with a single signature by the community physician who assumes oversight of the patient’s home healthcare
  • The physician who cared for the patient in the acute or post-acute setting is the certifying physician and has provided and signed attached documentation of the face-to-face encounter

In the statement the agency clarifies its expectations and cites the CY 2011 HH PPS final rule and the Medicare Benefit Policy Manual (BPM).

CMS goes on to say that it does not require that a specific form be used for the certification or the plan of care. However, many providers have chosen to use the CMS-485 form to satisfy the plan of care and the certification. The document states that:

Assuming all content requirements of the certification and the face-to-face documentation are otherwise met, in the case of patients admitted to home health following an acute or post-acute stay, Medicare contractors have been instructed to accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the requirement of the certification…

In the document, CMS states that it has also come to the agency’s attention that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient. CMS states that it has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician.

ACMA Involvement
In both Capitol Hill meetings and our efforts through the Face-to-Face Coalition that began in March, ACMA has urged CMS to permit the use of Form 485 to meet the documentation requirement.

To read the CMS statement, click here.

To read ACMA’s letter to Jonathan Blum, Director Center for Medicare and Centers for Medicare and Medicaid Services, click here.

Following Capitol Hill meetings, ACMA requested that members of Congress send a letter to Dr. Donald Berwick regarding the Face-to-Face requirement. To read the letter, click here.

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