NAHC Members Urged to Share their Face-to-Face Encounter Documentation Denials in a Survey

Recently two of the CMS contractors a have announced widespread audits of home health providers with a key focus on compliance with the face-to-face (F2F) encounter documentation requirements. The documentation requirements have become more stringent recently with contractors now expecting physicians to write detailed descriptions of the patient’s condition in order to support the need for skilled services and homebound status.

NAHC has heard that one contractor has denied 399 claims out of 801 within an 11-day period related to the revised guidelines for the F2F documentation.

Given the urgency of this issue for NAHC members – as well as the ramifications that it has for access to home health services – NAHC members recently were asked to urge lawmakers to sign-onto a Dear Colleague letter specifically on the new F2F requirements.

75 Members of Congress signed the letter that was recently sent to CMS Administrator Tavenner, stating that:

“As implemented by CMS, physicians are now required to document, sign and date an additional form with a narrative of the patient’s condition in order to justify home care services. Home health agencies must obtain this signed form prior to billing for Medicare home health services... Prior to billing for Medicare home health services, home health agencies already must obtain a signed and dated form from the physician which outlines the full plan of care…We have heard from home health agencies that believe as a consequence, these new forms are counterproductive to the underlying F2F intent.”

To view the full letter, as well as see the full list of signees, please see NAHC Report from September 25, 2013.

On the provider side, NAHC once again needs to present the case to CMS that home care agencies are in an untenable position with the more stringent F2F requirement guidelines.

NAHC is currently gathering solid data to present to the regulators from its members based on F2F requirement denials. NAHC has developed a survey with specific questions regarding the number and reasons for F2F denials, and asks its members to take a few moments to offer their insight.

The following survey should only take a few minutes to complete and will provide us with valuable information.

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