CMS Holds First Open Door Forum for the F2F Voluntary Templates
February 13, 2015 11:04 AM
On February 11, The Centers for Medicare & Medicaid Services (CMS) held the first in a series of Special Open Door Forum (ODF) calls on the voluntary electronic and paper face-to-face (F2F) encounter templates they developed. CMS released the templates to the public on January 30, and announced their intent to conduct an ODF to further discuss the templates with stakeholders.
During the call, CMS briefly reviewed the revised regulation for the F2F encounter that eliminated the narrative requirement for the encounter. Since the narrative is longer required, CMS will look at other documentation within the physician’s record to determine a beneficiary’s eligibility for Medicare home health, such as functional status to support homebound.
The templates are an attempt by CMS to assist physicians in documenting patient conditions and characteristics on a progress note that support the eligibility for Medicare home health services.
Both templates run five pages long and contain a combination of narrative and check box responses. The templates also contain skip patterns so that the entire progress note may not need to be completed
The electronic template is a revision of a previous version that was part of project within CMS and the Office of the National Coordinator. That project was placed on hold in mid 2014, and resumed several weeks ago. However, CMS admitted that they had never attempted to develop a paper template before.
During the question and answer portion of the call CMS only entertained inquiries regarding the templates and did respond to questions on the F2F regulation. Many callers expressed concern with the length of the templates and the need to still provide a narrative that describes why the patient is need of skilled service and reason for homebound.
One viable solution to these concerns, which was suggested by several of the participants, was to create a template with pre-determined language and check boxes that describe the various reasons skilled services are needed and homebound.
Although CMS was concerned that adding predetermined language would increase the length of the template, they were receptive to the idea, which is a reversal for them regarding the F2F encounter documentation. In the past, CMS maintained that a document with only checkboxes would not include enough content required to support eligibility.
The National Association for Home Care & Hospice (NAHC) supports a document with predetermined language and checkboxes. Any template put forth by CMS for the F2F encounter must be convenient for physicians to use. NAHC believes a template that contains predetermined language could be developed in less than five pages and will likely be better received by physicians, In addition, such a template can be designed to include enough content within the predetermined language to support a beneficiary’s eligibility for home health services.
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, 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.
To view the F2F templates and the slide deck from the presentation, please click here.
Comments can be sent to HomeHealthTemplate@cms.hhs.gov.
CMS will be hosting three additional ODFs on March 11, 2015, April 8, 2015, and May 6, 2015 all scheduled for 1:00PM ET.