CMS Hold Its Third Special Open Door Forum on the F2F Encounter Templates
May 21, 2015 03:54 PM
On May 20, the Centers for Medicare & Medicaid Services (CMS) held the third Special Open Door Forum call for the voluntary electronic clinical template for the home health face-to-face (F2F) encounter.
The CMS officials presented the latest version of both the electronic and paper templates. As with the other versions, the revised versions for both the electronic and paper templates follow the subjective, objective, assessment and plan (SOAP) model for documentation. The paper version is two pages and consists predominately of questions requiring a narrative response, while the electronic version is a combination of questions that require a narrative response and checkboxes. CMS included with this revised version a “Progress Note Guidance” page that describes the purpose of the template and the criteria for the home health certification, including the F2F encounter.
The presenters reminded participants that the templates are not mandatory but can serve as a physician progress note and/or guide for documenting the F2F encounter for patients who are referred to home health care.
CMS informed participants that before the templates can be released they must first go through the Office of Management and Budget approval process, which CMS estimates will take approximately 6 months. A notice will first be published in the Federal Register allowing for a public comment period.
The majority of the call was dedicated to a question and answer period. Many of the questions were related to process issues, specifically, when a physician’s co- signature would be required on the F2F encounter document. CMS could not provide a definitive answer to these questions since they are currently reviewing their policies on co- signatures on the F2F encounter document. Additional questions revolved around whether support staff and other members of the care team could assist with completing the template, whereby the physician would sign and date the document. CMS was clear that the progress note must be completed by the physician or the allowed non-physician practitioner.
The National Association for Home Care & Hospice did receive confirmation during the call that outstanding question related to the F2F requirement which have been submitted to CMS are being reviewed. CMS Officials stated they plan to publish further guidance in the Medicare Program Integrity Manual.
CMS will continue to accept comments on the templates but requests that comments be submitted as quickly as possible. Feedback and questions on the templates can be sent to: HomeHealthTemplate@cms.hhs.gov.
Click here to view the revised electronic and paper F2F encounter templates.