Beneficiaries should be aware that a new requirement stemming from the Health Care Reform legislation went into final force and effect on April 1, 2011. This requires that, with regard to home health agency (HHA) services, a physician must actually see a beneficiary face-to-face prior to certifying their need for home health agency care. This face-to-face encounter must occur within a 120-day window which begins 90 days prior to the start of care and ends 30 days after the start of care. In addition to a physician, a nurse practitioner, a clinical nurse specialist, a certified nurse-midwife, or a physician assistant may perform this encounter under certain circumstances. Additionally, the “face-to-face” may be performed via telemedicine, again, in certain circumstances.
And for hospice services, the new legislation requires a hospice physician or nurse practitioner to have a face-to-face encounter with a hospice patient prior to the patient's 180th-day recertification and at each subsequent recertification. (Hospices are periodically required to recertify a Medicare patient’s eligibility for hospice care.)
Beneficiaries need to be aware of some of the implications of this. For beneficiaries in hospice care, it’s pretty straightforward. It’s up to the hospice to make sure this is done, and done by one of their own physicians or practitioners. So you will not be liable for the cost of this encounter. And, if it is not done, and done timely, and the hospice continues to treat you, Medicare will not pay them, but they and not you bear the cost for any care you receive.
For home health agency care, it’s more complicated. For one, and this is not expected to be the norm, if the encounter is the only reason you need to see a physician, or other qualified practitioner, you are responsible for your share of the cost the encounter, which is a covered Part B service. On the other hand, it is up to the Home Health Agency serving you to make sure this new requirement is met. If for some reason they begin visiting you, and the encounter does not take place, they must notify you that you will become liable for all of their services (as Medicare cannot pay them unless this requirement is met). And if they do not notify you, you are not liable for the costs of their services.
Home Health Agencies have been instructed to notify you using the Home Health Advance Beneficiary Notice (HHABN), and more specifically, Option 2 of that notice. They are supposed to do this in advance of their stopping care so you can make arrangements for the encounter.
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