Upcoming Changes to Face-to-Face Requirements in Home Health: What You Need to Know

As the clock ticks down to the end of 2024, significant changes are on the horizon for the use of telehealth in home health care, specifically for the Face-to-Face (FTF) encounter requirement. These changes could have a profound impact on how agencies and providers meet compliance and deliver care. Here’s what you need to know about the current situation and what it means for your organization. 

Telehealth Waivers Ending December 31, 2024 

During the COVID-19 Public Health Emergency (PHE), a waiver allowed the patient’s home to serve as the originating site for telehealth visits, enabling providers to complete the FTF encounter via telehealth. This flexibility was a game-changer, making it easier for providers to comply with Medicare requirements and improving access for patients. 

However, this waiver is set to expire on December 31, 2024. Without new legislation, agencies will no longer be able to accept FTF encounters conducted via telehealth from the patient’s home. Instead, the originating site must revert to rural health clinics (RHCs) or federally qualified healthcare centers (FQHCs) as it was prior to the PHE. 

The Push for New Legislation 

The National Alliance for Care at Home (NACH), formerly NAHC and NHCPO, is actively working to extend this flexibility by advocating for new legislation. However, as of now, no bills have been passed, and time is running out. Industry experts, including Katie Wehri from NACH, note that “telehealth and other issues are in a state of flux,” leaving many agencies uncertain about what to expect in 2025. 

What This Means for Home Health Agencies 

1. FTF Encounter Compliance: Agencies should prepare to pivot back to pre-PHE practices, ensuring that FTF encounters for home health services are conducted in RHCs, FQHCs or other approved originating sites. 
2. Provider Education: Clarify with referring providers that the physician’s ability to bill for telehealth visits does not extend to using telehealth for the validation of the FTF requirement for home health. 
3. Hospice Care Eligibility: The same expiration applies to the use of telehealth for hospice care eligibility recertification. Without an extension, telehealth for this purpose will also end on December 31, 2024. 

Why It Matters 

This change could significantly impact patients who rely on the convenience and accessibility of telehealth from their homes. Providers and agencies will need to adjust workflows and ensure compliance with Medicare’s evolving requirements. The urgency to address this issue is growing, as the industry awaits potential last-minute legislation to extend telehealth flexibilities. 

What’s Next? 

With legislation still in flux, agencies are encouraged to: 

• Stay informed about updates from NACH and other industry leaders. 
• Educate providers on the pending changes to ensure proper planning. 
• Advocate for legislative action by reaching out to representatives and supporting NACH’s efforts. 

Final Thoughts

As 2025 approaches, the home health industry faces critical changes to telehealth practices that could disrupt workflows and access to care. While last-minute legislation may provide relief, it’s essential for agencies to prepare now and remain adaptable to whatever changes come next.

Stay tuned for updates and advocate for policies that support the flexibility and accessibility of home health services.