Congress Issues Report to CMS Asking it to Justify its Face-to-Face Policy
Report accompanied the 2015 omnibus continuing resolution that funds the government through FY 2015
Congress has sent a report to the Centers for Medicare and Medicaid Services (CMS) asking the agency to justify its face-to-face requirement. The House and Senate report, which accompanied the recently passed 2015 omnibus appropriations bill, says that CMS should “quantify and explain how the policy directing physicians to conduct face-to-face certifications for home health care has prevented fraud, increased access to health care, and impacted costs to the Medicare and Medicaid programs” as part of its fiscal 2016 budget request.
Additionally, the report Congress sent to CMS states that CMS should include ways to simplify the provider documentation for face-to-face encounters as part of its fiscal 2016 budget request.
With the new face-to-face documentation requirements scheduled to take effect on January 1, 2015, Congress’ report is the latest in a series of requests that CMS reevaluate its face-to-face requirements. Last week, both NAHC and its affiliate Forum of State Associations sent separate letter to CMS asking for a phase-in approach to enforcement of the face-to-face requirement. To date, CMS has not issued any guidance or initiated any education on the new requirement that physicians have sufficient documentation in their own files to support the certification of homebound status and skilled care need.
As part of its analysis of the ongoing face-to-face issue, Inside Health Policy recently summed up the continuing frustration the home care and hospice community feel surrounding the face-to-face requirement:
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