New Requirements for Home Health Certifications
Patient Protection and Affordable Care Act (PPACA) of 2010 provisions mandate new requirements regarding face-to-face encounters for certifications applicable to the home health program. The Centers for Medicare & Medicaid Services (CMS) recently updated the Home Heath Services chapter in the Medicare Benefit Policy Manual to implement these new conditions of payment.
Effective Jan. 1, a certifying physician or qualified non-physician practitioner (NPP) must document that he or she had a face-to-face encounter with a patient who requires home health services no more than 90 days prior to the start of care or within 30 days after the start of care. A second face-to-face encounter is required within 30 days after the start of care if the patient’s condition changes from what was documented in the visit made 90 days prior to start of care, and a change in treatment is required.
The face-to-face encounter can be performed via a telehealth service in an approved originating site. Legally authorized sites include: a physician’s office, hospital, critical access hospital (CAH), rural health clinic, federally qualified health clinic, hospital-based or CAH-based renal dialysis center, skilled nursing facility (SNF), or community mental health center.
If a qualified NPP provides the face-to-face encounter, the certifying physician must still document the encounter and sign the certification. According to CMS, a “qualified” NPP is considered to be one of the following:
- a nurse practitioner (NP) or clinical nurse specialist (CNS) working with the certifying physician in accordance to state law
- a certified nurse-midwife as authorized by state law
- a physician assistant (PA) under supervision of the certifying physician
The certifying physician or NPP must note when the face-to-face encounter took place and briefly describe how the patient’s clinical condition supports his or her homebound status and the need for skilled home health services. This documentation may be made on either the certification or an addendum to the certification. It may be handwritten, typed, dictated, or generated from an electronic health record (EHR). It may not be verbally communicated by the certifying physician to the home health agency for the facility to document.
The most important things to remember are that both the certification and the documentation of the face-to-face encounter must be prepared and dated by the certifying physician, and the certification must be signed by the certifying physician.
Exceptions to these conditions of payment are:
- If a home health patient dies shortly after admission to an HHA, but before the face-to-face encounter occurs, the certification is deemed complete as long as the contractor determines a good faith effort was made by the HHA to arrange the face-to-face encounter and all other certification requirements are met.
- An encounter between the patient and attending physician who cared for the patient during an acute/post acute stay may satisfy the face-to-face encounter requirement if:
- the attending physician certifies the need for home health care based on his or her contact with the patient and establishes and signs a plan of care, but does not follow the patient in the community; or
- the attending physician certifies the need for home health care based on his or her contact with the patient and initiates the orders for home health services, but transfers the patient to a designated community-based physician to review and sign off on the plan of care.
See CMS Transmittal 139, issued Feb. 16, to read the revised policy in Pub. 100-02, Medicare Benefit Policy Manual, chapter 7, section 30.5.11.