Inside Health Policy Analyzes Home Care Community’s Response to CMS’ Proposed F2F Template
NAHC’s Vice President for Law, William A. Dombi Quoted in Article
February 19, 2015 12:13 PM
Inside Health Policy recently ran an article on the response CMS’ proposed Face-to-Face (F2F) template is receiving from within the home care community. The article, “Home Health Groups Say New Face-To-Face Form Won't Solve Problems,” reports that the home care providers have offered a luke-warm response to CMS’ proposed template.
The article states that:
“A new proposed guidance from CMS is designed to ease the confusion over the face-to-face standards by replacing the narrative from doctors with a standardized form, but home health groups are not sure the optional form will make much difference or change the three-year trend of the increase in payment denials since the requirement began.
The face-to-face requirement began in 2011 as part of the Affordable Care Act. The measure aims to stop fraud by requiring Medicare patients who want to receive care in their homes to first visit their primary doctors, who must write narratives of office visits to document the need for home care…
Based on complaints from home health agencies, HHS changed the requirements at the first of the year, instead saying that MACs could review doctors' records to determine whether patients need home care.
That change did not deal with the three years worth of claim denials. Although appeals worked through the administrative law system have largely been overturned, Smith said there is a two-year backlog in the system…
Bill Dombi, vice president for law for the National Association of Homecare & Hospice, said his members share the same concerns.
"So far our membership feels it needs to be improved from top to bottom, starting with the length," he said, adding they'd also like guidance on how much they can help doctors complete the form, beyond just writing in the patient's name.
He is also concerned about the narrative portions that accompany the check boxes.
"Given the years of difficulty with the narrative, why would they make the form a narrative?" he said.
Dombi said they will submit comments on the form and participate in a Feb. 11 call the agency scheduled.
Both groups [NAHC and the Visiting Nurses’ Association of America] are still trying to get their members paid for the numerous claim denials, although they are taking different approaches.
VNAA is primarily working with Congress, hoping they can force CMS to review the claim denials from 2011-2014…
Dombi is leading a lawsuit against HHS, and the agency has until April to submit their first brief to the U.S. District Court for the District of Columbia.
"We're also talking to CMS about a middle ground settlement. I can't say we've made a lot of progress, but I can't say we've made no progress in that dialogue," he said.
Dombi said he would like to come up with a process for reviewing the denied claims, using a standard that would be "more reasonable than a narrative."
He said there are $250 to $400 million in denied claims that are still awaiting review that could also be decided based on the new standards.”
To read the full article, please click here.
To take action urging your lawmakers and CMS to modify the F2F requirements, please click here.