Face to Face for Medicaid & Telehealth

CMS has released the effective date of the new F2F ruling for Medicaid home health services.  July 1, 2016 is the official date.  However, states will be allowed to phase in the new F2F requirement by either July 1, 2017 or July 1, 2018. The delays are based on the time frame that a state’s legislature meets as some states do not have full time legislatures spewing tax increases.


The final rule imposes the following new compliance on Medicaid F2F:

  1. The referring physician who orders home health must document that a F2F encounter has occurred no more than 90 days before the start of services or 30 days after the start of services. The encounter must be related to the primary reason for required home health services and be documented.
  2. If medical equipment is ordered, the physician must certify that within a 6 month period that a F2F encounter has occurred for the primary reason of ordering the necessary equipment.


The final rule also indicates that besides a physician, certain NPPs may perform the F2F encounter.  Also, new clarification is provided for the definition of medical supplies and equipment.
Within the final rule, there is also a provision for physicians to conduct a video based conference with a patient to satisfy the requirement, but without very clear explanations as to what this means.  The only clear requirement is that for telehealth to be allowed for Medicaid purposes whether it is F2F encounters or as part of the care process.  Email and telephone calls do not count.  A video based system is necessary.  As more information becomes available, we will report back.