NAHC Submits Comments on the F2F Template
October 16, 2015 08:56 AM
The National Association for Home Care & Hospice (NAHC) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the clinical template for the home health face-to-face (F2F) encounter.
CMS announced its plan to develop a F2F clinical template in February 2015 and hosted a series of Open Door Forum calls to obtain stakeholder feedback. CMS developed the template as a tool to assist physicians with medical documentation to support coverage ofhome health services. The template will be voluntary and may be used as either a paper or electronic progress note.
The primary concern NAHC has with the proposed F2F clinical template is the amount of free text that it contains, specifically the items to justify skilled service and homebound. Both the free text and the prompts within this template are very similar to the F2F encounter document physicians were completing when a narrative to describe eligibility criteria for home health services was required. NAHC does not believe physicians will be more able to complete the template with the language and specificity that CMS seeks than when the physician was required to complete a F2F encounter narrative.
In addition, there is an error in the statement in the Progress Note that reads: “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.” We believe this statement is incorrect. The discharging physician is only required to identify the physician who will be following the patient if the discharging physician is the certifying physician. The identification of the physician who will be following the patient in the community was implemented to meet the criteria for certification that the patient is “under the care of a physician”
Further, the template contains conflicting guidance from what other CMS officials have stated regarding co-signatures on the F2F encounter. The template would require a co-signature by the certifying physician when an acute–post acute care physician or allowed NPP completes the F2F encounter. According to CMS, the elimination of the narrative removes the requirement that the F2F encounter be cosigned by the certifying physician when the encounter is performed by another eligible entity.
Lastly, NAHC believes CMS has underestimated the burden that the template will place on physicians. Due to the significant amount of free text only fields in addition to the specificity that will be required to complete the template, NAHC estimates it will take the physician twice as long to complete the Progress Note than what CMS has estimated.
After CMS reviews the comments, the template will need to go through the Office of Management and Budget approval process. Therefore, it may take several more months before the template is available for use.