CMS: For approval of Medicaid home health services, telemedicine counts for face-to-face visits

The Centers for Medicare & Medicaid Services published a final rule clarifying requirements for face-to-face encounters for Medicaid beneficiaries to be eligible to receive home health services; the rule outlines that telehealth can be used for such encounters. To authorize home health services via aides, nurses, equipment and/or appliances, CMS mandates that recipients must have a face-to-face encounter related to the reason for the request either 90 days prior to or 30 days after start of services. CMS says physicians and certain non-physician practitioners must document the encounters, which can be conducted via telehealth, "subject to requirements in section 1834(m)" of the Affordable Care Act. Some of the comments on the proposed rule were in support of telehealth, CMS notes.

One person was "pleased that CMS [was] ready to offer technical assistance to state Medicaid agencies to use telehealth as an alternative so that the requirement" could be implemented in a manner that allows for the continuation of services. "Telehealth and telemedicine are service delivery modalities that have very specific protocols that ensure quality patient care, and do not include all electronic communications," CMS says. The agency notes that telephone calls or e-mail will not suffice for face-to-face encounters, but puts the onus on states to determine which forms of telehealth can be used.