Face-to-face requirements set to kick in tomorrow

This from the Visiting Nurse Associations of America.  In short... bad news for home care agencies and the most vulnerable patients they serve.

VNAA Disappointed with CMS Decision and Pledges to Continue Improving Face-to-Face Requirements.

(Washington, DC) – March 31, 2011 – Jonathan Blum, Center for Medicare Management Director, notified the Visiting Nurse Associations of America (VNAA) and other national organizations via phone today that the Centers for Medicare and Medicaid Services (CMS) will stick with full enforcement of the face-to-face encounter provision effective April 1.

During the call to Kathleen Sheehan, Vice President of Public Policy for the VNAA, Blum said that CMS felt it was time to move forward with full implementation and that it would carefully monitor any problems that patients might face with access. While the face-to-face provision was put into effect on January 1, 2011, a grace period of 90 days had been granted by CMS before financial penalties for noncompliance would be levied.

The phone call was made to Sheehan in her role as the convener of a coalition of national organizations that have worked with CMS over the past couple of months to iron-out expected problems with implementation. Members of the coalition, which includes AARP, the American Hospital Association, the Catholic Healthcare Association, the American Medical Association, American Case Management Association, the Society of Hospital Medicine and the National Association for Home Health and Hospice had met with Jonathan Blum and CMS on several occasions to address implementation issues and asked that the grace period on financial penalties be extended for another 90 days to provide time to educate physicians about their new responsibilities and make system changes. The coalition's effort was unprecedented in terms of bringing together such a wide spectrum of beneficiary and provider groups behind regulations that impacts payment for home health and hospice services.

“We are deeply disappointed that more time was not provided as there was a strong consensus among diverse groups that it takes about 6 months for an educational and system change of this magnitude," said Andy Carter, VNAA President and CEO. "Our nonprofit members are most likely to take the risk of serving patients who may not have a primary care physician and may not be able to get the documentation done within the timeframe. Our goal now is to work with VNAA members and others to document and report the problems implementing this provision that will most certainly delay or limit access to care for some patients. ”

Carter also noted that while VNAA members and the Face-to-Face Coalition were not able to win a further grace period, they have worked hard to convince CMS to make the implementation less onerous and that they will continue to do so.

For more information, visit the VNAA's Face-to-Face Webpage http://vnaa.co/F2Fhelp.