Face to Virtual Face

Expansion of telehealth services and vaccine news are included in this report.

The Patient Protection and Affordable Care Act (PPACA) established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. Documentation of such an encounter must be present on certifications for patients with starts of care on or after January 1, 2011. The regulation has been fully implemented and providers are complying with the requirements.

Expansion of Telehealth With 1135 Waiver 
Under the waiver, Medicare started paying for office, hospital, and other visits furnished via telehealth across the country and including in patient’s places of residence starting March 6, 2020.  A range of providers, such as doctors, nurse practitioners, clinical psychologists, and licensed clinical social workers, are able to offer telehealth to their patients.  Additionally, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs.

So, can home health and hospice providers use telehealth to meet the face-to-face requirement in the first 90 days?  The answer is yes with some restrictions.  The face-to-face has to be with the physician or their assistant that is connected to the patient.  There are questions about whether “ad-litum” billing, where  on a limited basis physicians can bill under another physician’s billing number for short periods of time can use telehealth for face-to-face meetings.  That being said, telehealth could help home health and hospice providers with a cost effective and compliant way of meeting billing requirements.

CMS Increases COVID-19 Vaccine Fees
In other news, Medicare increased the payment amount for administering the COVID-19 vaccine. The concept was that the higher rate would incentivize providers to give more shots and support providers and provider sites. The supply of vaccine is growing and soon the bottleneck will not be the amount of vaccine, but the number and locations of vaccine sites.

Effective for COVID-19 vaccines administered on or after March 15, 2021, the national average payment rate for physicians, hospitals, pharmacies and many other immunizers will be $40 to administer each dose of a COVID-19 vaccine. This represents an increase from approximately $28 to $40 for the administration of single-dose vaccines, and an increase from approximately $45 to $80 for the administration of COVID-19 vaccines requiring two doses. The exact payment rate for administration of each dose of a COVID-19 vaccine will depend on the type of entity that furnishes the service and will be geographically adjusted based on where the service is furnished.  

The Centers for Medicare & Medicaid Services (CMS) stated that the updates resulted from new information about the costs for administering the vaccine.  It also seems to be driven by the impact of variants of the COVID-19 virus and concern about getting the economy back on track and children back in school.

CMS is also updating toolkits for providers, states and insurers in conjunction with the increased rate for giving the vaccine.  Let’s all do what we can by promoting vaccination with our friends, families and co-workers.  Tell people when you get vaccinated.  Post it on social media.  Let’s be our brother’s (and sister’s) keeper. 

 Program Note: Listen to Monitor Mondays, April 12, 10 a.m. Eastern when William Dombi, president of the National Association for Home and Hospice, will be the broadcast’s special guest.


Timothy Powell, CPA

Timothy Powell is a nationally recognized expert on regulatory matters, including the False Claims Act, Zone Program Integrity Contractor (ZPIC) audits, and U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) compliance. He is a member of the RACmonitor editorial board and a national correspondent for Monitor Mondays.

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