Policy Manual sample
MDT Home Health Care Agency, Inc. POLICY ON FACE TO FACE ENCOUNTER PURPOSE: The Affordable Care Act mandates that all patients receiving Medicare home care services must have a face to face encounter with a physician or Non-Physician Practitioner (NPP) (If the referral Physician work in collaboration with a nurse practitioner or a clinical nurse specialist, or supervise a physician’s assistant.) POLICY: The Agency will comply with this regulation, and enforce the face-to-face encounter that can take place up to 90 days before the patient is admitted to home care services (the start of care visit). A face-to-face encounter is required for certifications, rather than initial episodes; and that a certification (versus a re-certification) is generally considered to be any time a new start of care assessment (Start-of-Care OASIS assessment) is completed. If the face-to-face encounter does not occur prior to the start of care visit it must be completed within 30 days from the date on which home care services were initiated. The face-to-face encounter and the documentation of the encounter is a requirement for reimbursement of all Medicare home health services. PROCEDURE: 1. Distribute the CMS Face to Face educational materials (Fact Sheets) to our patients, referral sources, discharge planners, and physicians, to help understand the regulation. 2. Use of our Patient Information letter regarding Face to Face regulation. 3. If is not possible that the referred patient comply with this regulation, bring to him/her the NON ACCEPTANCE letter. 4. If the patient was admitted into care without having the qualifying encounter within 90 days prior to the start of care, or within the 30 days following the start of care, bring to them the “Notice of Potential Liability for Charges” (within the first 21 days of services), informing them of the possible responsibility for all charges for care from the start of care until termination of care, or remind them to inform us when they have had the qualifying encounter. 5. If the patient was admitted into care without having the qualifying encounter within 90 days prior to the start of care, and after the 30 days following the start of care was not possible comply with the regulation, bring to them the “Notice of Termination of Care” informing them of the termination of our services. 7. Send to all referrals Physician and explanation letter that accompanied the “DOCUMENTATION GUIDE”. 8. Encourage to all of our referrals physician comply with CMS Documentation Guide for Face to Face encounter that must comply with: Made by the physician responsible for certifying home health (or non-physician practitioner as described above). Related to the primary reason for which the patient requires home health services. Made within 90 days prior to, or within 30 days of, the start of home health. Home Health Agency Policies A-154
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