Home Health Face-To-Face Requirement and the OIG Work Plan
The Office of Inspector General 2013 work plan included a new provision that relates to the home health “face-to-face” requirement. The face-to-face requirement was included in the Patient Protection and Affordable Care Act. A face-to-face encounter must occur with the physician within a 128 day timeframe; either within the 90 days before beneficiary start home health care or up to 30 days after care begins.
The OIG work plan states that the OIG will determine the extent to which home health agencies are complying with the statutorily required face-to-face physician certification requirement for home health patients.
Home health agencies by now are familiar with the face-to-face requirements but should take this opportunity to audit themselves for compliance. Policies should be put in place which require compliance with the face-to-face certification. The home health agency should monitor ongoing physician activities to assure that the encounter and certification are appropriately documented in the patient’s medical record. Failure to do so will expose the organization to compliance risk.
If you need any information regarding the home health face-to-face requirements or compliance issues for home health care providers, please do not hesitate to contact our offices.
