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Face to Face Encounter Requirements

Tuesday, June 6, 2017   (0 Comments)
Posted by: Mandy Rubenstein
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Legislation passed as part of the Health and Human Services Omnibus Finance bill contains specific direction for the state in coming into compliance with this new federal mandate. The language states that a face-to-face encounter by a qualifying provider must be completed for all home health services regardless of the need for prior authorization, except when providing a one-time perinatal visit by skilled nursing. The face-to-face encounter may occur through telemedicine as defined in statute. The encounter must be related to the primary reason the recipient requires home health services and must occur within the 90 days before or the 30 days after the start of services. The face-to-face encounter may be conducted by one of the following practitioners, licensed in Minnesota: (1) a physician;(2) a nurse practitioner or clinical nurse specialist;(3) a certified nurse midwife; or(4) a physician assistant. The allowed nonphysician practitioner performing the face-to-face encounter must communicate the clinical findings of that face-to-face encounter to the ordering physician. Those clinical findings must be incorporated into a written or electronic document included in the recipient's medical record. To assure clinical correlation between the face-to-face encounter and the associated home health services, the physician responsible for ordering the services must:(1) document that the face-to-face encounter, which is related to the primary reason the recipient requires home health services, occurred within the required time period; and (2) indicate the practitioner who conducted the encounter and the date of the encounter. For home health services requiring authorization, including prior authorization, home health agencies must retain the qualifying documentation of a face-to-face encounter as part of the recipient health service record, and submit the qualifying documentation to the Commissioner or the Commissioner's designee upon request.

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