We’re excited to share that the use of telehealth for face-to-face encounters has been extended until September 30, 2025.
The extension permits both home health and hospice to continue conducting face-to-face encounters on behalf of home health. However, if the encounter is conducted via telehealth, the platform used must be HIPAA-compliant, and the encounter note must document that both audio and video were utilized. Audio-only encounters are not allowed.
With this extension, we are also pursuing legislation that could make the telehealth allowance for face-to-face encounters permanent, though it has not been finalized at this time.
In addition to this update, it’s important to highlight some of the most common reasons face-to-face encounters are denied for both home health and hospice.
Top Two Common Home Health Denials Reasons
For home health, the first reason face-to-face encounters are denied under Medical Review or not affirmed during the pre-claim review process is because the encounter was not completed by an allowable provider. If a patient was admitted to an inpatient facility, the face-to-face encounter from that facility is only valid if the patient was discharged directly to home health. Additionally, if the encounter was a community face-to-face encounter, it must have been performed by the certifying physician. If an MD is certifying the patient, a nurse practitioner working under that MD may also complete the face-to-face encounter.
The second common reason for denial is that the primary diagnosis for the home health encounter or admission was not addressed during the face-to-face encounter. The encounter documentation must clearly show that the physician or practitioner treated the patient for the condition that is the primary focus of the home health episode.
Top Two Common Hospice Denials Reasons
The leading reason for face-to-face denials in hospice is timing. The encounter must take place within 30 days before the start of the benefit period in which it is required. For the third and subsequent benefit periods, a new face-to-face encounter is needed for each period, and it must also occur within the 30-day timeframe before the benefit period begins.
Another common reason for denial is insufficient documentation within the face-to-face encounter to support the patient’s ongoing terminal prognosis. It’s also important to remember that the content of the face-to-face encounter must be incorporated into the clinical narrative of the Certificate of Terminal Illness.
Whether for home health or hospice, it is crucial that the face-to-face encounter is properly documented and appropriately focused. Before beginning a home health episode or a hospice benefit period, ensure that the documentation is complete and supports the patient’s situation, especially in the event of a Medical Review.
Healthcare Provider Solutions is here to help with any face-to-face encounter issues you may encounter. Please don’t hesitate to reach out to us.
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