Reed letter urges simpler process, more access to home health services

Rep. Tom Reed recently spearheaded a letter to the administrator of the Center for Medicare and Medicaid Services asking that CMS review the Physician Face-to-Face Encounter Requirement – a duplicative and costly burden being implemented as part of Obamacare. Reed was joined on the letter by 75 bipartisan members of Congress, with the support of dozens of state home care and hospice organizations.

“Those who care for our aging and ailing family members and loved ones are relaying to us that the new regulations increase paperwork and cost to their organizations that are already struggling to provide affordable home care,” Rep. Reed said. “On behalf of the home health provider community and the millions of elderly and disabled individuals who receive vital services, we are asking that CMS review an expensive and unnecessary regulatory burden that presents an unfair barrier to patients receiving home health care services. The last thing we want is to provide a disincentive for physicians to recommend home health services.”

Under the Face-to-Face rule, physicians are required to submit duplicative documentation that already exists under Medicare regulations, including the patient’s “plan of care,” assuring physician involvement in the authorization process, and providing justification for Medicare services. Many hospitals, particularly rural hospitals, are finding this redundancy especially burdensome given the financial strain they are already under.

In the letter, Reed and his colleagues ask that the regulation be reviewed.

“While we support the need for direct encounters between patients and physicians to occur, the current regulations contain complicated, confusing, and overlapping documentation requirements that exceed the intent of the law passed by Congress. These requirements have imposed a significant burden on home health providers and physicians in our districts,” he said.

Local health care providers view the new requirement as similarly problematic.

“Physicians play a vital and well-established role in the process of authorizing home health care services,” Cattaraugus County Health Department Director of Patient Services Susan Andrews said. “Unfortunately, for the past two years, home care service providers have been required to document physician authorizations using new, duplicative protocols which are simply not feasible in a care delivery environment that involves coordination of providers across geographic distances and remote care settings. I applaud Congressman Tom Reed for working with New York’s home care community in urging federal regulators to adopt a more reasonable approach to the face-to-face requirement by simply modifying the existing, well-established protocols for physician documentation.”

Home Care Association of New York State President Joanne Cunningham said, “Since it was implemented two years ago, the Medicare face-to-face documentation requirement has only created enormous new cost pressures for providers seeking to comply with the complex and duplicative mandate. Worse yet, the current requirements have also placed undue limitations on access to care for the vast majority of Medicare beneficiaries whose clinical conditions are, without question, supported by the Medicare benefit and determined by the physician as requiring home care services. HCA greatly appreciates Congressmen Reed’s leadership in seeking a solution that maintains the important bridge between a home care provider and its physician community while mitigating the administrative burdens on both.”

Rep. Reed is currently involved in a number of issues on the home health care front, including his Hospice Evaluation and Legitimate Payment Act, his Rural Hospital Access Act, and the Preventing and Reducing Improper Medicare and Medicaid Expenditures Act.