Medicaid Face-to-Face Compliance

The Centers for Medicare & Medicaid Services’ (CMS) Medicaid Home Health final rule was published on February 2, 2016 with an effective date of July 1, 2016. States are required to comply with these provisions, however, as indicated in the final rule, CMS recognizes that states may experience operational and budgetary implications that states need to consider as they plan to implement certain provisions of the final rule. Therefore, CMS delayed compliance with the final rule for up to two years from the effective date, based on state legislative cycles. 

CMS continues to work with states and regulators to ensure the implementation of the Medicaid face-to-face regulations. CMS issued guidance to discuss areas of flexibility that could be granted to states in the implementation.

As articulated in the final home health regulation, the regulation sets forth a framework for coverage, and does not remove state flexibility to define the scope of the home health benefit. States continue to have flexibility to establish a reasonable service definition if that definition is consistent with the federal regulatory framework.

CMS remains committed to providing technical assistance to states and other stakeholders in understanding the Medicaid Home Health final rule and developing implementation approaches that maximize the provision of Medicaid services in a manner compliant with program requirements. If you have questions or would like to request technical assistance, please send an email to

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