The Centers for Medicare and Medicaid Services (CMS) released a new regulation on February 2, 2016 requiring patients who receive Medicaid benefits for home healthcare services to have a face-to-face visit.

“Specifically, the final rule requires that for the initial ordering of home health services (nursing services and home health aide services), the physician must document that a face-to-face encounter that is related to the primary reason the beneficiary requires home health services occurred no more than 90 days before or 30 days after the start of services.” This regulation will go into effect on July 1, 2016 for all Medicaid patients. This ruling is very similar to the Medicare ruling in an effort to simplify beneficiaries’ access, provide consistency and reduce burden on the home care agencies.

Being Homebound No Longer Required for Medicaid Home Care

I remember a time when all of the home care patients on my caseload were required to be homebound. They were limited to going to medical appointments and very few exceptions were permissible. There were times when I had to discharge a patient because they had been going out to dinner with their spouse. It was always a very fine line that we had to walk in order to ensure that the patient was meeting the home care guidelines. Under the new regulation, patients are no longer required to be homebound. This is going to make home care services accessible to a great deal of people that previously would not qualify.

“For the initial ordering of medical supplies, equipment, or appliances, the physician or authorized NPP must document that the face-to-face encounter occurred no more than six months prior to the start of services. In addition, for medical supplies, equipment, and appliances, physicians or certain authorized non-physician practitioners (NPPs) must document the occurrence of a face-to-face encounter with the Medicaid eligible beneficiary within reasonable timeframes. This process can include the use of telehealth.”

There are some noteworthy points that I want to share regarding this new regulation.

• The face-to-face regulation will go into effect on July 1, 2016
• The encounter must relate to the patient’s need for home health services (nursing services and home health aide services)
• The face-to-face encounter must occur no more than 90 days before or 30 days after the start of care date
• Patients do not need to be homebound
• Certain medical equipment will require a face-to-face no more than six months before the start of care. Telehealth is an eligible face-to-face encounter

For more information follow the link below:

https://www.medicaid.gov/medicaid-chip-program-information/by-topics/benefits/downloads/health-home-factsheet.pdf

To learn more about the Medicaid regulations and how to best manage your offerings, contact Richter Healthcare Consultants at 866.806.0799.