CMS aligning Medicaid and Medicare home health requirements

Last week, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that adds new requirements for Medicaid home health services. Among the new requirements is that physicians document a face-to-face encounter with Medicaid patients before ordering the home health services or certain related medical equipment. This rule aligns Medicaid with similar regulatory requirements for Medicare.

Specifically, the final rule requires that when first ordering home health services (nursing services and home health aide services) the physician must document that a face-to-face encounter related to the primary reason the patient needs home health services took place no more than 90 days before or 30 days after the start of services. If initially ordering medical supplies, equipment, or appliances, the physician or an authorized non-physician provider (NPP) must document that the face-to-face encounter occurred no more than six months prior to the start of services. In both cases, the physician or certain authorized NPPs must be the one performing the face-to-face encounter.

The final rule is effective on July 1. However, CMS recognizes that state governments and physicians may need time to deal with the operational and financial effects of the changes. Accordingly, CMS is delaying compliance with this rule for up to one year (July 1, 2017) if a state’s legislature has met in that year or two years (July 1, 2018) if not.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians