Enforcement delayed for face-to-face requirement

CMS to enforce rule on April 1, 2011

In a welcome move, the Centers for Medicare and Medicaid Services (CMS) has announced a three-month suspension in enforcement of the hospice and home health face-to-face recertification requirements that were in effect on Jan. 1, 2011. The suspension followed a meeting between National Hospice and Palliative Care Organization's (NHPCO) leadership and CMS officials.

The delay in enforcement did not eliminate the requirement that hospice providers implement procedures to meet the face-to-face requirement on Jan. 1, but Medicare Administrative Contractors (MACs) were alerted in late December that enforcement of the requirement is suspended until April 1, 2011.

During the first quarter, NHPCO and CMS will work together to answer additional questions and resolve ongoing interpretations and implementation processes. NHPCO has posted a list of frequently asked questions to assist providers. To see a copy of the FAQ document, go to www.nhpco.org/files/public/regulatory/FAQs_Face-to-Face_v2.pdf.