CMS Holds Face to Face Call
December 18, 2014 09:47 AM
The Centers for Medicare & Medicaid Services (CMS) held a long-awaited National Provider call on the revised home health face-to-face encounter requirements for certifying Medicare home health patients. The revisions go into effect January 1, 2015.
The CMS officials presented an overview of the requirements for home health eligibility, along with the revisions made in the final rule relative to the face-to-face encounter. CMS reiterated that the narrative requirement will no longer be required for initial certifications beginning January 1, 2015. CMS did emphasize that a brief narrative is required for certifications and recertifications for patients receiving skilled nursing for Management &Evaluation of the Care Plan.
Although the narrative has bee eliminated, all other aspects of the face-to-face encounter are still required, such as the encounter must occur no later than 90 days prior to or 30 after the start of care; is related to the primary reason for home health service; and is performed by a physician or an allowed non physician practitioner. CMS will apply the face-to-face encounter requirements anytime a new state of care Outcome and Assessment Information Set (OASIS) is required.
CMS confirmed that they will review the certifying physician’s record to ensure documentation supports eligibility for home health services. Agencies must obtain the physicians record if the agency’s claim is targeted for medical review.
Additionally, the presenters provided various examples of progress notes and discharge summaries and highlighted what CMS will be looking for when reviewing the medical record to support eligibility for home health services. As currently required, acceptable documentation would include the physician detailing why a patient needs skilled service and reason(s) for homebound. If the physician’s documentation does not substantiate a patient’s eligibility, CMS will permit the agency to fill in the “gaps” by providing the physician with information that supports the need for skilled service and homebound status. The physician would be required to sign any documentation received from the agency and incorporate it into his/her own medical record
Although agencies are not required to obtain the physician’s documentation prior to billing, CMS recommends that agencies obtain as much information, as soon as, possible, from the physician to ensure eligibility requirements have been met. CMS also stated that they plan to initiate probe reviews for physicians who have a pattern of referring patient that do not meet the home health eligibility requirements. However, they did not provide details on how this would be implemented.
During the Q&A session of the call, CMS addressed several question related to the specifics of acceptable documentation needed to comply with the revised requirements.
The agency could incorporate their findings that support eligibility for home health services in the POC for the physician to sign. What is unclear is will the agency be required to include portions of the assessments that supports theses findings.
The face-to-face narrative document currently used by physicians will not be required to document home health eligibility. CMS will look at the physician’s record for support of home health eligibility and must include the actual visit note from the encounter or a discharge summary if the patient is admitted to home health after an acute-post care facility stay.
CMS indicated that the physician’s encounter note would need to only include the date of the encounter, be related to the primary reason for home health, and be signed and dated by the certifying physician. The agency could fill in the “gaps” by supplying the physician with information from their assessment that supports eligibility, but it must corroborate with the physician’s documentation . It still unclear what CMS will accept as sufficient corroborating documentation from the physician?
The National Association for Home Care & Hospice (NAHC) has serious concerns about some of the information conveyed and positions taken by CMS. Specifically, NAHC is concerned about the depth of documentation that CMS is expecting from physicians. NAHC is also concerned about the standard that documentation from the HHA alone is insufficient to support the physician certification and that it can be used only if it corroborates other documentation not prepared by the HHA. Lastly, CMS did not address or even seem to appreciate the burden it will be for both physicians and agencies to obtain the physician’s record. And what are agencies to do if the physician does not cooperate?
NAHC will continue to work with other stakeholders and communicate with CMS to have the concerns of home care and hospice providers addressed.
The audio recording and written transcript of this MLN Connects Call will be posted here once it is available.