End Of Virtual FTF Visits For Home Health And Hospice
CMS just announced an update to the 1135 waiver information, including end dates for each waiver. This will impact the FTF visits for both home health and hospice.
HOSPICE:
Under the PHE waiver, face-to-face recertification visits for all 60-day benefit periods can be completed via telehealth. CMS announced that the PHE will have an end date of 5/11/23. CMS is allowing a grace period after the PHE ends, concluding on December 31st, 2024. This additional extension was made possible due to the Consolidated Appropriations Act (CAA) of 2023. All FTF visits, beginning January 1, 2025, must be in person.
Page four of the CMS Release states: "Face-to-face encounters for purposes of patient recertification for the Medicare hospice benefit can now be conducted via telehealth (i.e., two-way audio-video telecommunications technology that allows for real-time interaction between the hospice physician/hospice nurse practitioner and the patient). The Consolidated Appropriations Act, 2023 extended telehealth flexibilities through December 31, 2024, regardless of the status of the PHE."
(Note: Originally, CMS had published this guidance from the Social Security Act on 2/6/23 stating the telehealth for FTF was ending 151 days after the PHE ended. But the new CAA overrides this with the extension through the end of 2024. This error was corrected on 2/7/23. CMS also seemed to have a typo, as they reported December 3, 2024, but it is in law for December 31st. We expect a correction soon)
HOME HEALTH:
The face-to-face visit, required for eligibility at the SOC for Home Health benefits, has a waiver allowing the visit to be provided remotely as long as there are audio and video components documented. This PHE also has a new end date of 5/11/23. CMS is allowing a 151-day grace period after the PHE ends to continue accepting remote FTF visits. This would conclude the grace period on Monday, October 9, 2023. All FTF visits, beginning October 10, 2023, must be completed in person. See page four of the CMS Updated Fact Sheet for Home Health waivers for more information.