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New Medicare Requirement for Face-to-Face Encounters

  • Published: 2010-12-18 : Author: National Association for Home Care & Hospice
  • Synopsis: New federal regulation issued by Medicare will create crisis for approximately 4.5 million home health and hospice service patients.

Main Document

New Medicare Requirement for 'Face-to-Face' Encounters Could Have Negative Consequences for Home Health Care and Hospice Patients.

A new federal regulation issued by Medicare in November will create a crisis for approximately 4.5 million home health and hospice service patients. Starting on January 1, homebound elderly and disabled patients as well as hospice patients will now need to have a "face-to-face encounter" with a physician or nurse practitioner if they want to receive care under Medicare.

The National Association for Home Care & Hospice (NAHC) understands the intent of the new rule is to maintain benefit integrity by ensuring strong physician involvement in care planning and authorization, however, is strongly encouraging Medicare to examine the implementation process. NAHC is calling for a transitional period of no less than six months after the rule is enacted, wherein Medicare can monitor for compliance, provide notice of noncompliance where appropriate, provide continuing education on the requirements, and institute changes in instructions and guidelines where needed.

"There may be valid reasons for this new regulation, but we anticipate major disruptions in access to hospice and home health care as most affected people, doctors included, have not even heard of the new rule yet," said Val J. Halamandaris, NAHC President.

Elderly and disabled Medicare beneficiaries who are confined to their homes for medical reasons or hospice patients in the midst of end of life care will need to find a way to either get to the doctor or get the doctor to come see them. This is the predicament that will result if considerations for home care and hospice needs are not made.

"Physicians' orders drive all health care services under Medicare, but face-to-face meetings should not be required to authorize home health care for patients who by definition must be homebound in order to qualify for services," said Halamandaris.

Ensuring the right to be cared for in our homes is America's last great civil rights battle. The goal of NAHC is to help frail, disabled and dying Americans stay independent and happy in the comfort of their homes. Medicare should not jeopardize this with its overly hasty implementation of the "face-to-face" rule, without testing it first and without sufficient time for everyone involved to understand what is required of them.

About NAHC - The National Association for Home Care & Hospice (NAHC) is a non-profit organization that represents the nation's 25,000 home care and hospice organizations. NAHC also advocates for the more than two million nurses, therapists, aides and other caregivers employed by such organizations to provide in-home services to some 10 million Americans each year who are infirm, chronically ill, disabled and dying. Along with its advocacy, NAHC provides information to help its members provide the highest quality of care and is committed to excellence in every respect. To learn more about NAHC visit and

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