VA_Lisa Morgan

I would like to request that CMS drop the face to face requirement altogether. It has not accomplished the purpose most likely intended for Medicare recipients and has only been a barrier to service for patients whom need care and cannot get in to see their physicians due to financial contraints, i.e. a bedbound patient requiring ambulance transport. The requirement is simply duplicate documentation on the plan of care where the physician is certifying the need for skilled care, the services needed, the diagnoses supporting the need. For our agency, the face to face encounter has not been terribly difficult to obtain, but the physician compliance with documentation has been horrific. Despite multiple education efforts and re-education efforts physicians do not have the time to handwrite this required documentation and puts agencies at extreme risk of losing reimbursement. This is the experience of home health agencies across the country. We truly want to be able to serve the patients in collaboration with their physicians but this type of duplicate regulatory requirement is a barrier to access of care not an enhancement. Please only make changes that will improve care or access to care, not put up barriers!