tci Medicare Compliance & Reimbursement - 2011 Issue 12

Compliance: Steer Clear Of F2F Violations With Medical Directors

Face-to-face rules may be different for another physician's patients. Do you know when it's OK for your medical director to perform the face-to-face encounter and accompanying documentation -- and when it's not? A new F2F frequently asked question might lead you in the wrong direction, one legal expert warns.The question: "Can a home health agency Medical Director or physician perform the face-to-face encounter?" a questioner asks the Centers for Medicare & Medicaid Services in a FAQ posted on its website in May.The answer: CMS's answer seems direct enough: "If the financial relationship between a home health...

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