New Physician / Patient Face-to-Face Encounter Requirement

It has been brought to our attention that under the new health care reform law, under section 6407, home health agencies will be responsible for assuring that physicians or other practitioners who refer a patient for home health or hospice recertification had a face-to-face encounter with the patient. Apparently, the encounter can’t be more than six months prior to referral.   One agency has suggested adding wording to the certification section of the 485 to the effect that the physician or acceptable person from the physician’s employment  as had a face-to-face encounter with six months.  We would like your suggestions on how this might be accomplished.  You can fax us at 814 834-9355 or e-mail me davef@softhhc.com.  Thanks.