Payment Matters: CMS Proposes Medicaid Face-to-Face Requirements for Home Health and Medical Supplies and Equipment

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Home health agencies, still struggling to meet the Medicare face to-face requirements that went into effect last spring, will also have to deal with similar requirements for their Medicaid patients. CMS issued a proposed rule on July 12, 2011 that would provide that, in order for a physician to order home health services or medical supplies, equipment or appliances (called for convenience "medical equipment"), the physician or a permitted non-physician practitioner (NPP) must have a face-to-face encounter with the patient. The proposed rule also clarifies where and to whom Medicaid home health services can be provided and elaborates on the definition of medical equipment. The comment period ends on September 12, 2011.

Medicaid Face-to-Face Requirements

In accordance with the provisions of the Affordable Care Act, CMS proposes, generally, to adopt the same face-to-face requirements for Medicaid home health and medical equipment as it has for Medicare home health and durable medical equipment (DME). See "Therapy Changes, Face-to-Face Encounter Provisions and Enrollment Changes are Highlights of CY 2011 Home Health PPS Final Rule." The following are some of the highlights of the proposed rule...

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