CMS Issues Face-to-Face Documentation Template
January 30, 2015 02:08 PM
As home health agencies continue to struggle to understand and apply the new documentation requirements under the physician face-to-face encounter rule, CMS has unveiled a form for voluntary use that may help. The form is based on an Electronic Health Record (EHR) project within CMS and the Office of the National Coordinator. It is a slimmed-down revision of the earlier EHR version and covers only the F2F elements rather than a full scale clinical assessment of the patient.
The template is available in two versions: electronic and paper. These draft templates can be accessed by following the links below.
CMS will be holding Open Door discussions of these draft templates. However, they can be used now by home health agencies. CMS intends the templates to be for purely voluntary use and will not mandate that physicians or HHAs use them. CMS intends the completed form to be part of the physician’s record, thereby fulfilling the requirements of the new rule that took effect on January 1.
On first glance, you will see a 5 page form. You will also note that CMS indicates that the form must be completed by someone other than the HHA, but not necessarily the physician. The prospect of a physician completing a 5 page form is daunting, but it uses a combination of check boxes and directed questions that should speed things up for the physician.
Given the voluntary nature of the form, HHAs and physicians will still be able to achieve documentation compliance by other means such as using existing documents such as the hospital discharge summary and the HHA OASIS assessment provided the certifying physician has signed off on them and includes them in the patient’s record. Still, those compliance standards remain foggy for the home health community despite the CMS teleconference in December.
In early December, NAHC requested that CMS phase in the new documentation requirements in a multi-step process that includes a hold on F2F documentation related claim denials until adequate guidance is issued, comprehensive training is completed, and physicians are given the opportunity to demonstrate that the documentation standards are understood. At this point, CMS has not determined if it will adopt that request. Instead, it appears that CMS wants to move forward, using the voluntary form as the means to compliance.
NAHC remains committed to working with CMS on establishing a temporary hold on claim denial. HHAs should do everything possible to comply with the documentation requirements in the meantime. In addition, HHAs should convey their F2F concerns and any difficulties to CMS immediately, as CMS continues to consider our phase-in request.
Also, in discussions with CMS this week, it was indicated that CMS intends to have its contractors re-prioritize their audit resources. In doing so, the audits will shift away from pre-2015 F2F issues, e.g. the notorious narrative, and refocus on compliance with the new standards. This does not mean that CMS will stop auditing pre-2015 claims altogether. Instead, any such audits will be focused on non-F2F issues or limited, targeted F2F audits. The details and specifics on this change are not available.
NAHC continues to prosecute its F2F lawsuit with the design of fully stopping audits on compliance with the narrative requirement and remedying past claim denials based on insufficient narratives. In the interim, HHAs should fully consider administrative appeals of any pre-2015 F2F-related claim denials.