Effective July 1, agencies will have to comply with a face-to-face encounter requirement for Medicaid home health care, similar to the requirements for Medicare.
 
A final rule was posted on the Federal Register Jan. 27, more than three years after the rule was initially proposed.
 
When the rule takes effect, the timeframes for face-to-face encounters will be the same as for Medicare home health. Patients will be required to see a physician within 90 days before or 30 days after the start of services.
 
CMS notes that agencies might face “operational and budgetary implications” due to the requirement — and that states and providers might need time to prepare. As a result, it will delay compliance for one to two years, depending on when an individual state’s legislature meets.
 
The final rule also requires that for the initial ordering of certain medical equipment, the physician or authorized non-physician practitioner (NPP) must document that a face-to-face encounter related to the primary reason the beneficiary requires medical equipment occurred no more than six months prior to the start of services.
 
“The face-to-face encounter for home health and medical equipment may be performed by the physician or certain authorized NPPs,” the rule states. “The final rule maintains the role of the physician in ordering Medicaid home health services and medical equipment.”
 
One way the Medicaid requirement differs from the Medicare requirement is that it could be met through a telehealth delivery model recognized by the state as a physician or NPP encounter under its approved state plan.
 
Having a face-to-face requirement for Medicaid will increase program integrity, resulting in more quality home health services for Medicaid beneficiaries, according to the rule. “Additionally, this rule will potentially serve to provide individuals with disabilities a greater ability to engage in normal activities of daily living.”
 
Related link: View the final rule at http://bit.ly/1SKP6Lm.