PA-Dennis Munko

Thank you for the opportunity to submit comments on the proposed Medicaid rule. It is a pleasure to serve the Medicaid population. Relative to Medicaid implementing face-to-face (f2f) we definitely believe that requirement will negatively impact patient access and serve as a barrier to care because of the additional administrative burden to physicians in filling-out the f2f form. Physicians simply do not like this requirement. With the imposition of the f2f requirement for Medicare patients we have noticed some decline in overall referrals from physicians. That pattern is likely to also occur when f2f is implemented for Medicaid patients. Additionally, considering the fact that typically home health agencies such as ourselves do not cover our costs through Medicaid reimbursement when serving Medicaid patients, the additional administrative burden that would be placed on home health agencies because of f2f will further exacerbate that problem. The f2f requirement for Medicaid patients seems to be unnecessary given the fact that in our state of Pennsylvania visits must be pre-authorized and therefore approval of visits is obviously predicated on the fact that there is a clinical need for skilled care. Again, we appreciate the opportunity to submit comments. Thank you for your consideration.