NHPCO Meets with CMS
To: NHPCO Members
From: NHPCO Regulatory Team
Re: December 21, 2010
Breaking News: 3-month suspension of enforcement of Face-to-Face Requirement announced (12/23/10)
NHPCO Meets with CMS to Voice Concerns with Face-to-Face Rule
Summary at a Glance:
NHPCO leadership met with officials from CMS earlier today to continue dialog regarding the many concerns the hospice community has with the hospice face-to-face encounter rule required for recertification. Chief among the concerns expressed at today’s meeting were the problems with the Common Working File and the recent update to the HIPAA Eligibility Transaction System (HETS) that has been met with unexpected complications. NHPCO strongly emphasized that hospice providers will have difficulty in checking patient eligibility given the problems with these two systems. Additional discussion involved whether the face-to-face visit and recertification may be done by the same physician.
NHPCO invites members to review the letter shared with CMS officials today.
NHPCO has been working to make the position of the hospice community clear to officials at CMS since the final rule was released in mid-November.
Given that the rule is expected to go into effect on January 1, 2011, NHPCO reminds members that a number of tools and resources have been created to help with compliance in the recertification process. These materials may be downloaded from the Regulatory and Compliance section of NHPCO’s website:
- Medicare Hospice Regulations with Updated regulatory text at 418.22 – Certification of the Terminal Illness
- CMS Hospice Face–to-Face Final Rule – November 2010
- Recertification of Terminal Illness tip sheet
- Sample Recertification of Terminal Illness forms and instructions for use
- Recertification Care Map
- Recertification of Terminal Illness Audit Checklist
- PowerPoint Presentation for Use in Staff In-Service Education
Below, NHPCO’s Regulatory Team offers some Frequently Asked Questions that have been asked by hospice providers. (Download the following FAQs in PDF, revised 12/23/2010.)
Hospice Face-to-Face Encounter Regulations
Member inquiries should be directed to firstname.lastname@example.org. Additionally, a new “Face-to-Face” e-group and library have been created on NHPCO’s member-only professional networking site, My.NHPCO. This is an additional online resource that may be of help to providers.