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Home Health & Hospice Week

Compliance:

Steer Clear Of F2F Violations With Medical Directors

Published on Tue May 03, 2011

Face-to-face rules may be different for another physician's patients. Do you know when it's OK for your medical director to perform the face-to-face encounter and accompanying documentation -- and when it's not? Anew F2F frequently asked question might lead you in the wrong direction, one legal expert warns. The question: "Can a home health agency Medical Director or physician perform the face-toface encounter?" a questioner asks the Centers for Medicare & Medicaid Services in a FAQ posted on its website in May. The answer: CMS's answer seems direct enough: "If the financial relationship between a home health agency physician or a Medical Director  satisfies the requirements of an exception in 42 CFR §411.355 through §411.357, he or she may perform the face-to-face encounter and subsequently certify home health eligibility." The regulatory citation refers to the Stark physician self-referral law. Under the F2F requirements, there is "a large temptation to have an [...]
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