We understand that during the RCD webcast this morning, Palmetto stated that for all SOCs dated on or after October 1, 2025, the face-to-face encounter must be conducted in person. The Alliance contacted Palmetto for clarification and reminded them that the F2F encounter may occur up to 90 days prior to the SOC date for certain patients. We also cited a CMS publication indicating that the September 30, 2025, telehealth extension applies based on the actual date the patient receives a telehealth service, (MLN901705 - Telehealth & Remote Patient Monitoring).
Palmetto confirmed our interpretation and agreed that F2F encounters occurring within the permitted timeframes-including those performed up to 90 days prior to the SOC date-will be considered.
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Mary Carr
Vice President, Regulatory Affairs
National Alliance for Care at Home
Washington DC
+1 (202) 547-7424
mcarr@allianceforcareathome.org------------------------------