CMS Call for VNAA Members on Final Medicaid Face-to-Face Rule
Tuesday, February 16, 2016
by: Visiting Nurse Associations of America

Section: Quality and Educational Programming

CMS finalized a proposal on the Medicaid face-to-face requirement; the rule is effective July 1, 2016. 
Join VNAA Thursday, February 18, 2016 at 12pm ET for a webinar 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 questions. Click here to register.

Highlights of the rule include: 
  • 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 may be done by a 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 state will provide specific details on what they will require.
  • Clarification that there is no "homebound" requirement to receive home health services in Medicaid.
  • Clarification 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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