Face To Face Encounters CY2011 Clinical Compliance

CMS was mandated by the Affordable Care Act to provide this encounter. You will be able to look on page 296 on the Final Rule to read the depth of it. But, essentially what CMS is stating is that the physician must see the patient within 90 days prior to the admission in a home health agency.  And that means that also, in seeing that patient for that face-to-face encounter, that diagnosis or that reason for seeing that patient must be directly related to the home health referral.  Now, if they don’t see them within 90 days prior to they must see them within 30 days after admission.

As of December 10, 2010 CMS is sending out a notice to the physician regarding this face-to-face encounter information.  So the home health agencies are going to have to do a lot of education with physicians.  It also requires then, that the physician provide this attestation that they have completed this face-to-face encounter, and it has to be attached to/or a part of the POC.

At Select Data we’ve created a documentation of the face-to-face encounter tool click here to download a copy of this form: DocumentationFacetoFaceEncounter.pdf

Summary

The face to face encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. While the long standing requirement for physicians to order and certify the need for home health remains unchanged, this new requirement assures that the physician’s order is based on current knowledge of the patient’s condition