Medicare Policies Should Put Patients Before Paperwork

Programs designed to help safeguard and improve the health of our nation’s seniors should not cause increased stress or unnecessary burdens. Unfortunately, that is exactly what’s happening for the healthcare professionals who have dedicated their professional lives to caring for Medicare’s elderly and disabled home health patients.

The culprit? Implementation of Medicare’s “Face-to-Face” requirement for home health beneficiaries.

While the intent of this rule makes sense, practical application of the face-to-face requirement hasn’t. The current law requires a physician to document that a face-to-face encounter with a beneficiary occurred in order to certify eligibility for Medicare home health services. But because the requirements for how this encounter is to be documented are unclear and burdensome, patients and their providers have been forced to contend with claim denials and an often lengthy appeals process.

To date, thousands of claims have been denied for medically necessary and appropriate care because of poorly designed and frequently misunderstood documentation requirements.

Through no fault of their own, many of the 3.5 million patients who rely on home health nurses, physical therapists and other clinicians have experienced delays or denials for their care. The face-to-face requirement, as currently structured, is confusing, cumbersome and inconsistently administered.

While the documentation rule is designed to ensure beneficiaries are being referred to the most clinically appropriate care setting, the true result is that paperwork is getting in the way of patients.

Home health leaders are asking policymakers to recognize the flaws of the face-to-face requirement and take action so that we can ensure our vulnerable patients, and their care, remain paramount. Studies show that patients who depend on home health are older, sicker, poorer and are more likely to be female, a minority, and disabled than all other beneficiaries in the Medicare program combined. Unnecessary interruptions in their care due to problems with claims can be disastrous.

Recognizing the need for change, lawmakers including Reps. Greg Walden (R-Ore.) and Tom Price (R-Ga.) are developing commonsense legislation that will improve today’s unworkable and administratively burdensome documentation rules.

Their reform will reduce the paperwork burden on physicians and home health agencies, minimizing the risk of inappropriate denials of care. That simple change is possible by directing CMS to utilize a standardized form, developed in consultation with stakeholders, to document beneficiaries’ eligibility for home health services. Also of real importance, this plan will enable delayed claims to be processed so that care can proceed without interruption.

Aging Americans are growing in number and, with each passing year, deserve exceptional, consistent care, free from erroneous claim denials and red tape. They also deserve the confidence that their skilled clinicians will be able to devote their valuable time to patient care, not paperwork. This commonsense reform will achieve both, strengthening Medicare’s home health program for years to come.


Eric Berger is the CEO of the Partnership for Quality Home Healthcare, a coalition of the nation’s leading innovators of home healthcare dedicated to improving the integrity, quality, and efficiency of home healthcare.

Morning Consult