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Initial Episode Clarified for Home Health Face-to-Face Encounter

CMS requires a patient receiving HH services under the Medicare HH benefit have a FTF encounter with the certifying physician for the initial episode. CMS has clarified that this is required for all initial episodes or SOC episodes. This is a change from instructions CMS has in their question and answer document (answer 11) regarding the HH FTF.

There are some instances where the physician certifying HH care and the HHA may not realize a FTF is required. 

  1. A patient is receiving HH services but is hospitalized on day 60 (the last day of one episode) and day 61 (the first day of the next episode of continuous care). When HH services resume following this hospitalization, the CMS IOM Publication 100-04, Medicare Claims Processing Manual, Chapter 10, Section 80B requires that the new episode to be billed as a new SOC claim. This will require a new FTF encounter document.
  2. A HH patient is hospitalized and is discharged on day 60 or day 61. If the HHA performs a ROC assessment that changes the HIPPS code from a recertification assessment performed in the last 5 days of the previous episode, this must be reported as a SOC assessment prior to submission to the state agency. This is a new SOC, and a FTF is required.
  3. A beneficiary is admitted to the hospital in the first days of an episode prior to delivery of services in the new episode. This is handled the same as the discharge on day 60 or 61 above. The episode will be considered a SOC if the HIPPS code is different from the recertification assessment performed in the last five days of the previous episode.
  4. A HH patient changes insurance from Medicare Advantage to Medicare FFS. The claim for Medicare FFS will be a SOC claim, and a FTF is required.

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Initial Episode Clarified for Home Health Face-to-Face Encounter
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