Association takes on face-to-face rule

Friday, March 28, 2014

WASHINGTON – The National Association for Homecare (NAHC) is laying the groundwork for a possible lawsuit against CMS’s implementation of the face-to-face requirement for home health, according to AAHomecare. The association says providers are frustrated with denials related to the face-to-face requirement and believe CMS needs to provide more guidance and clarity. Arguments for the lawsuit include: Claims shouldn’t be denied for lack of documentation if it is present in the rest of the medical record; the requirement for the narrative is outside the authority granted to CMS by the Affordable Care Act; and CMS isn’t following Medicare due process requirements to publish clear, concise guidelines. The NAHC plans to talk with beneficiary advocates, disability groups and others about joining the lawsuit. AAHomecare plans to monitor its progress closely.