A coalition of 13 prominent medical societies and senior citizen advocacy groups has sent a letter (PDF) to Center for Medicare Management Director Jonathan Blum requesting that he postpone enforcement of a new CMS rule requiring an initial "face-to-face" encounter between clinicians and certain Medicare patients before the patient qualifies for coverage. They also asked that documentation requirements of that encounter be simplified.
Med societies ask CMS to delay enforcing 'face-to-face' rule
The rule (PDF) stems from section 6407 of the Patient Protection and Affordable Care Act, and it requires that Medicare home health and hospice patients meet with a physician or a nurse collaborating with a doctor before they can qualify for Medicare coverage. Implementation was originally scheduled for Jan. 1, but was then pushed back to April 1.
Citing other reform-related deadlines dealing with implementing electronic health-record systems and ICD-10 diagnostic codes, the letter requests a postponement of rule enforcement to no earlier than July 1. Among the letter's signees are the American Medical Association, the American College of Physicians, the American Academy of Family Physicians, the American Osteopathic Association and the AARP.
"The primary barrier to compliance is the paperwork burden on physicians," according to the letter. "A secondary barrier is getting certain patients to see a physician/NPP (nonphysician practitioner) face-to-face."
The letter calls for eliminating a requirement in the rule mandating that physicians supply a "narrative to justify why the physician believes that the patient has a life expectancy of six months or less." The letter recommends that physicians need supply only a signed statement that the encounter took place or use a modified version of the existing Physician Certification and Plan of Care government form for this documentation.
"Also, the dust is still settling around what is required, so assurances of compliance are unlikely," according to the letter. "The extension sought will allow for resolution of any interpretive issues, comprehensive awareness action and full 'dry run' testing. The results of 'dry run' testing to date are in, and they indicate that all parties are not ready."
The CMS has said the rule's intent is to ensure that care is provided based on a patient's current health situation.
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