Patient home transfers call for encounter, documentation

Offering guidance for physicians, non-physician practitioners, physician support personnel and home health agencies, the Centers for Medicare & Medicaid Services clarified last week that it requires face-to-face encounters and documentation when providers transfer hospital and other patients to the home health setting. 

To meet certification requirements--and, by extension, home health payment requirements--a physician must certify that the patient needs home health services and has a care plan, according to the Medicare Learning Network article. The doctor or another nonphysician practitioner with privileges (i.e., nurse practitioners, clinical nurse specialist, certified nurse midwife or physician assistant) must have a face-to-face encounter with the patient within 90 days before the start of home healthcare or within 30 days after the start date, according to CMS. Providers can conduct the encounter remotely via telehealth technology, CMS said.

The physician also must record the face-to-face encounter, which serves as documentation when the home health agency bills Medicare.

The new Medicare rule is part of the U.S. Health & Human Services revamping of regulations in which it hopes to increase efficiency and alleviate administrative burdens on providers. HHS has reported "significant progress" in privileging and credentialing and documentation regulations for both in-person and telemedicine visits, in particular.

CMS last week revised the Conditions of Participation to offer regulatory relief and streamline operations between care facilities.

For more information:
- see the CMS Medicare Learning Network article (.pdf)
- see the home health Q&A (.pdf)

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