Health Information Compliance Alert

Don’t be afraid to appeal face-to-face denials.

Medicare’s latest F2F guidance revision gives home health agencies yet another reason to guard against face-to-face physician encounter-related denials (see related story above).

“Most providers I deal with are reviewing the content very, very closely and returning to physicians immediately requesting that the documentation be enhanced,” offers consultant Pam Warmack with Clinic Connections in Ruston, La. “This is a great deal of work and the physicians are obviously not happy.”

“Agencies need to appeal all of these denials to the highest level they can,” urges Judy Adams with Adams Home Care Consulting in Asheville, N.C. “Since [the Centers for Medicare & Medicaid Services] has not updated their questions and answers yet, I would doubly encourage all HHAs to appeal any denials on the basis of this new interpretation that has not even been published by CMS yet.”

“We can do nothing but comply with this regulation,” Warmack adds. “But surely something has got to change.”

Adams and Warmack urge providers to appeal to their legislators and work with industry representatives to secure change of the onerous requirement.

“The constant changes in interpretation to meet the face-to-face documentation requirements is one of the most egregious actions by CMS in many years,” Adams fumes. “This whole issue is enough to make anyone fighting mad.”