Second Comment Opportunity Announced for the F2F Clinical Template
January 11, 2016 12:04 PM
The Centers for Medicare & Medicaid Services (CMS) has announced a 30 day notice for public comment and the Office of 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.
This is the second public comment period opportunity for the template. CMS announced a 60 day public comment period on August 12, 2015. Based on those comments, CMS made several non-substantive changes to form but has maintained the same format.
The template is a combination of checkboxes and blanks for narrative documentation. The checkboxes relate primarily to the physician’s physical assessment of the patient, while documentation related to the reasons for skilled services and homebound requires a narrative explanation. The National Association for Home Care & Hospice (NAHC) stated in their comments during the first comment period that the free text within the template is 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 complete the clinical template with the language and specificity that CMS seeks.
NAHC also commented that the following paragraph on the form—“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”—conflicts with current CMS policy. The facility physician would only be required to identify the community physician if the facility physician is certifying the patient for home health services. CMS removed the paragraph from the revised form.
Comments are due January 27, 2016. To view the clinical template and supporting documentation click here.