OIG Releases Report on Home Health Face-to-Face Requirements

WASHINGTON (April 17, 2014)—On April 9, the Department of Health and Human Services Office of Inspector General (OIG) released a report titled “Limited Compliance with Medicare’s Home Health Face-to-Face Requirements.” This report is not related to the face-to-face requirements for DME. However, OIG undertook this study to determine the extent to which physicians who certified home health care documented the face-to-face encounter, described the nature of the face-to-face encounter, and assessed CMS oversight of the face-to-face requirement. OIG found that documentation did not meet Medicare requirements for 32 percent of the home health claims they reviewed that required face-to-face encounters. The result was $2 billion in payments that should not have been made. In addition, physicians inconsistently completed the narrative portion of the face-to-face documentation. OIG also found that CMS oversight of the face-to-face requirements is minimal. CMS concurred with the following three OIG recommendations: • CMS should consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation. • CMS should develop a specific strategy to communicate directly with physicians about the face-to-face requirement. • CMS should develop other oversight mechanisms for the face-to-face requirement.