CMS Clarifies Provider Action When Face-to-Face (F2F) Delayed

In the open door forum held November 2, CMS once again reversed its decision regarding what to do when a client fails to complete a F2F encounter within 30 days of start of care (SOC). The latest interpretation from CMS includes the following action steps and billing clarification when the face-to-face physician encounter doesn’t occur in the mandated timeframe:

• When the face-to-face physician encounter did not occur in the 90 days prior to the SOC or within 30 days after the SOC, the provider may complete another OASIS with the SOC equal to the date where all Medicare eligibility is met. Medicare will not pay for services before the date of eligibility.
• According to CMS, at the time the encounter is completed a new SOC OASIS assessment may be generated that reflects a SOC date equal to start of the beneficiary's Medicare eligibility
• A prior OASIS can be used to generate a new SOC OASIS
• For example, if a client completes a F2F encounter on day 35 of the episode, the eligibility date would be 30 days prior to the date of the F2F encounter. Therefore, the first 5 days would not be billable.

CMS bases this decision on the flexibility allowed when a beneficiary changes from another payer source to Medicare Fee-For-Service (see Section 80, Chapter 10 in the Medicare Claims Processing Manual). The manual allows for  OASIS completion flexibility in this situation to meet billing and eligibility rules.