CMS and its contractors can reopen claims for a period of three (3) years to determine if the provider of services met all qualification for payment of services provided.
Is it any wonder that two years after implementation of face to face (F2F) provisions of the Affordable Care Act that the Office of Inspector General (OIG) and Medicare Administrative Contractors (MAC’s) are conducting directed reviews of the F2F provision codified and effective April 1, 2011. Our clients are already experiencing medical record requests and denials as a result of the initiatives.
Simply having a F2F encounter documented in Medicare beneficiary medical records is not enough. Referral sources should be thoroughly trained on these requirements and due care taken by home health agencies to ensure compliant F2F documentation is present on each start of care.