|Posted by Denise Jones on February 18, 2011 at 7:56 PM|
Face to Face Transmittal It doesn't change anything significant, but CMS issued a transmittal yesterday to "clarify" the face to face rule. You can obtain a copy here.
The transmittal does clarify that it is okay for the physician to dictate the narrative, etc. for the face to face and to his the physician's staff transcribe it.
The transmittal also states that the physician cannot transmit the information to the HHA for the HHA to then document as part of the certification for the physician to sign.
The transmittal also provides an exception in the case of the death of the patient before the face to face occurs. The HHA must have made a good faith effort to facilitate the face to face and have met all of the other certification requirements. In that case, the certification is deemed to be complete.