CMS Reverses Stance on Medicare Advantage Face-To-Face, But Beware!

In a memorandum released on June 11^th to Medicare Advantage Plans, CMS clarified their position to Medicare Advantage Plans concerning Face-To-Face requirements for home health services.  The clarification states that the Medicare Advantage Plan’s authorization for home health services may substitute for the Original Medicare face-to-face certification requirement regarding authorization for covered services.  It says they are not required to follow Original Medicare documentation requirements for the provision of Medicare covered services, but may substitute methods they deem appropriate for ensuring that the services provided are medically necessary, so long as they are not more restrictive than the coverage standards that apply in Original Medicare.

This does not mean that a Medicare Advantage Plan cannot require Face-To-Face documentation for coverage of home health services.  It says they are not required to enforce this Original Medicare Standard.  Since Medicare Advantage Plans seem to adjust their requirements for coverage on the fly, it would probably be a good idea to obtain face-to-face documentation on Medicare Advantage Plan patients to make sure it is not retroactively applied at some later date.