CMS Proposes Clinical Template for the F2F Encounter
August 14, 2015 03:20 PM
The Centers for Medicare & Medicaid Services (CMS) has issued a notice for public comment and the Office and Management and Budget approval for the home health face to face (F2F) encounter electronic and paper clinical template. The template is a progress note that was developed to assist physicians in documenting the home health F2F encounter required for Medicare certification of home health patients. The use of the template is voluntary.
CMS held several Special Open Door Forums calls to present the F2F encounter clinical templates and to receive stakeholder input. The template is the result of the feedback received on those calls.
The template is a combination of checkboxes and blanks for narrative documentation. However the checkboxes relate primarily to the physician’s physical assessment of the patient. Documentation related to the reasons for skilled services and homebound requires a narrative explanation, similar to the old F2F encounter document agencies used when a narrative was required on the F2F encounter document.
CMS has added some additional language to this template that was not on the last draft version posted in May. On the template CMS includes the following:
“If the patient requiring home health services is being discharged to home from a hospital/acute care facility and the discharging physician will not be following the patient after discharge, then please identify the community physician who will be taking over care for the patient.”
The statement is misleading since acute/post-cute care physician only needs to identify the community physician who will be following the patient if the acute/post-cute care physician is the certifying physician. The requirement to identify the community physician is to satisfy the portion of the certification thatrequires services are or were furnished while the patient is or was under the care of a physician. If the acute/post-cute care physician is not the certifying physician there is no need to identify the community physician. In addition, there seems to be an error in the statement that reads: “If the patient requiring home health services is being discharged to home from a hospital/acute care facility….” The statement should read: “….a hospital/post-acute care facility…”
The National Association for Home Care & Hospice has concerns that the template will not be well received by physicians and/or will not be completed to the medical reviewers’ satisfaction.
Although CMS eliminated the narrative from the F2F encounter regulation, the template format essentially adds it back into the process for physicians certifying home health patients. Therefore, NAHC has reservations about its usefulness as a tool that will assist physicians in documenting eligibility criteria for Medicare home health services.
Comments on the form and burden estimate are due October 13, 2015. Click here to view the template and supporting documentation.