CMS Corrects Inaccurate Information on the Home Health F2F Requirement
March 27, 2015 07:31 AM
On March 11, the Centers for Medicare & Medicaid Services (CMS) held a Special Open Door Forums (ODF) for the voluntary electronic and paper clinical template for the home health Face to Face (F2F) encounter requirement. During that call one of the presenters provided inaccurate information regarding what would be acceptable documentation within the physician’s medical record to support home health eligibility.
Several of the participants, during the question and answer session of the call, questioned the presenters about the CMS policy that allows a physician to sign information from an agency’s assessment and incorporate it into his/her medical record to support eligibility. The CMS representative responded by comparing agency documentation to consultation notes that might be found in a physician’s record, concluding that CMS does not actually consider these documents to be part of the physician’s record, since they are not generated by that physician. CMS indicated it would only look for documentation the physician generated to support home health eligibility.
This interpretation is in conflict with what CMS clearly spelled out in the final rule for home health prospective payment system (HHPPS) rate update, and what was later presented during a national provider call.
The National Association for Home Care & Hospice contacted CMS regarding the conflicting information and requested clarification.
On March 24, CMS released the following:
“In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services. Per 42CFR 424.22 (a) and (c), the patient’s medical record must support the certification of eligibility and documentation in the patient’s medical record shall be used as a basis for certification of home health eligibility. Therefore, reviewers will consider HHA documentation if it is incorporated into the patient’s medical record and signed off by the certifying physician. More guidance will follow regarding the review of home health claims shortly. CMS apologizes for the confusion.”