Face-to-face encounter requirements remain a critical compliance focus for home health and hospice providers, especially in light of the recent government shutdown. Today, we provide clarification on current face-to-face encounter guidance and outline what providers need to understand as the situation continues to evolve.
The telehealth face-to-face encounter was scheduled to expire at midnight on January 30, and it did, as the government budget resolution was not passed. Although the legislation includes an extension of the face-to-face encounter requirement, it has not yet been approved. As a result, we are strongly advising home health and hospices agencies not to accept telehealth face-to-face encounters beginning January 31 and continuing until a resolution is reached.
Many may be relying on the fact that the previous extension was applied retroactively, but we cannot recommend taking that approach, as there is no certainty that any future extension would be applied retroactively.
Please remember that if an extension is granted, any telehealth face-to-face encounters must be documented by the provider to confirm that both audio and video were used and that the encounter occurred on a HIPAA-compliant platform.
For home health face-to-face encounters, please remember that under the final rule effective January 1, we are now permitted to accept face-to-face encounters from any qualified provider, provided the encounter meets all face-to-face documentation requirements. This includes ensuring the encounter date falls within 90 days prior to, or within 30 days after, the start of care, and that the documentation clearly supports the need for home health services as well as the primary reason for home care.
Healthcare Provider Solutions is here to support you with any questions or assistance related to face-to-face encounters or documentation for home health or hospice. If you need assistance, please feel free to reach out to us.
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