CMS Finalizes Medicaid Face-to-Face Rule
Tuesday, February 2, 2016
by: Visiting Nurse Associations of America

Section: Quality and Educational Programming




Last week, CMS finalized its proposed rule on the Medicaid face-to-face requirement, which takes effect July 1, 2016.

Join VNAA on Feb. 18, 2016 at 12:00 p.m. ET for a conference call with key leadership at the CMS Center for Medicaid and CHIP Services, Division of Benefits and Coverage. They will provide an overview of the final rule and answer VNAA member questions.


Rule Highlights:

  • The face-to-face visit for home health services must occur 90 days before or 30 days after home health services begin. This is aligned with the Medicare F2F timeframe. For initial medical supply orders, face-to-face encounters must take place no more than six months before services start. The F2F encounters can be done by telehealth through a telehealth delivery service approved by the Medicaid state plan. There is no face-to-face recertification requirement.
  • The F2F encounter my be done by physician or authorized non-physician practitioner. The rule maintains the role of the physician in ordering home health services 
  • The rule does not prescribe how documentation must be captured. The documentation should support the need for what was ordered. Each states will provide specific details on what they will require. 
  • Clarifies that there is no "homebound" requirement to receive home health services in Medicaid 
  • Clarifies that home health services cannot be restricted to care in the home 
  • Expands the definition of Medicaid covered medical supplies and equipment under the home health benefit, and clarifies that these supplies can't be restricted to the home.
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