Home Health & Hospice Week

CMS answers about face-to-face requirements raise more questions.

That face-to-face documentation you have signed by a resident won't do you any good when it comes to compliance and reimbursement.

That's because Medicare doesn't allow physicians who don't have hospital privileges to sign the F2F documentation, said a Centers for Medicare & Medicaid Services official in the April 11 Open Door Forum for home care providers. Residents who don't have privileges must inform their supervising/teaching physician who does have privileges, said CMS's Kelly Horney in the forum.

Clarification: CMS is talking about privileges to practice at the hospital, not Medicare billing privileges, CMS's Randy Throndset explained in response to a question from Mary St. Pierre of the National Association for Home Care & Hospice.

You'll also want to be leery of F2F documentation from Veterans Administration physicians, Horney indicated. Medicare accepts certification from physicians only when they are enrolled in Medicare, Throndset pointed out.

If the VA physician "moonlights" at another practice and is enrolled there, then Medicare would accept her F2F documentation, Horney said.

St. Pierre and other callers told CMS they found these answers confusing. CMS plans to issue written Q&As on the topics, Throndset pledged.

Meanwhile, don't hold out hope that CMS will get more understanding when your patients lack F2F encounters. Currently, CMS grants an exception to the F2F requirement only when the patient dies.

Sometimes despite an agency's best efforts, the patient is just not able to see the physician within 30 days of start of care, a HHA caller told CMS. For example, bad weather will cancel an appointment or the patient can't leave the home, she related.

CMS has no plans to expand the exceptional circumstances granted, Throndset told the caller.

Hospice F2F May Occur Same Day Benefit Period Starts

Hospices got a piece of good news about their face-to-face requirements. A valid F2F encounter may occur on the first day of the benefit period the F2F encounter covers, CMS's Katie Lucas said.

Medicare requires the hospice F2F to occur up to 30 days before the third or later benefit period begins. "This timeframe does not preclude" the benefit period starting and the encounter happening on same day, Lucas explained. "We allow hospice providers the flexibility to complete the face-to-face