Last week the Home Care Association of New Hampshire joined state home care associations across the nation to urge CMS to delay enforcement of the new Medicare Face to Face certifying requirements for physicians. The letter sent to Centers for Medicare and Medicaid Services (CMS) Administrator Marilyn Tavenner urged a phased-in approach to the new face-to-face documentation requirements. The new requirements are scheduled to take effect on January 1, 2015.
The letter highlights CMS’ past willingness to phase-in new requirements, as well as reiterating the challenges that both home health agencies and physicians will face if the new requirements are not phased-in:
“The new documentation requirement takes effect on January 1, 2015. However, CMS has not yet issued any interpretive guidance on the rule change nor has there been any educational efforts directed towards physicians or home health agencies on it. While an “Open Door” call is scheduled for December 16, it is highly likely that any information conveyed in that call will not be conveyed to all the physicians and home health agencies that care for home health patients sufficiently to bring about full compliance by January 1. It is also likely that there will be many unanswered questions remaining after the call that will require CMS to issue further guidance.