In accordance with the Patient Protection and Affordable Care Act, the Centers for Medicare and Medicaid Services modified certification and recertification guidelines for home health care and hospice services in April 2011. The new regulations require “face-to-face” encounters between physician and patient for certifying and recertifying home health/hospice services on or after Jan. 1, 2011.
- Home health care
Effective Jan. 1, 2011, physicians who certify a patient as eligible for Medicare home health services must see the patient in a face-to-face encounter within 90 days before the start of home health care or within 30 days after the start of care in order for the home health agency to be reimbursed.
Regulations allow the performance of a face-to-face encounter by a hospice physician, hospice nurse practitioner or hospice physician assistant. If the face-to-face encounter is performed by a hospice nurse practitioner or physician assistant, then the certifying physician:
- Must attest that he or she allowed a non-physician practitioner to perform the face-to-face encounter and provide the date of the encounter within the encounter documentation.
- Must attest to the patient’s condition found during the face-to-face encounter with the non-physician practitioner and in support of home health services.
- Must sign and date the certification form or append an attestation that includes a narrative of the patient’s condition (supporting home health services), the date of the face-to-face visit, acknowledge that he or she allowed the non-physician practitioner to perform the face-to-face exam, and the certifying physician must sign and date the attestation
- May dictate the addendum and provide a signature and date on the dictated page; however, verbal communication to the home health agency is unacceptable.
- Hospice services
Hospice benefit periods consist of two 90-day periods and an unlimited number of 60-day periods. The initial certification of terminal illness must be based on the clinical judgment of the hospice medical director or physician member of the interdisciplinary group and the patient’s attending physician, who can be a medical doctor, doctor of osteopathy or nurse practitioner. The initial certification is valid for the first 90-day benefit period. A recertification must be performed no later than 15 days prior to the second (90-day) benefit period.
Effective Jan. 1, 2011, a hospice physician or hospice nurse practitioner must perform a face-to-face encounter on the hospice patient within 30 days of the beginning of the third benefit period and for every subsequent (60-day) benefit period thereafter. The hospice physician or hospice nurse practitioner performing the encounter must attest in writing that he or she had a face-to-face encounter with the patient, provide the date of encounter, and sign and date the attestation. According to Medicare,
“the attestation, its accompanying signature, and the date signed, must be a separate and distinct section of, or an addendum to, the recertification form, and must be clearly titled. Under circumstances where a nurse practitioner performed the face-to-face encounter, he or she must state within the attestation that the clinical findings of the encounter were presented to the certifying physician in use for determining a life expectancy of six months or less.”
Access more information online:
Physician Certification and Recertification of Services Manual Changes
Medicare Benefit Policy Manual, “Chapter 7 - Home Health Services”
Medicare Benefit Policy Manual, “Chapter 9 - Coverage of Hospice Services Under Hospital Insurance”
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