Home Health & Hospice Week

Once enforcement for the new face-to-face requirement begins April 1, you're likely to see your referrals and admissions go down.

Industry veterans expect some physicians to stop referring home care patients, or at least as many patients as they currently do. "Some of our referring docs just might throw in the towel with this one," predicts Casey Blumenthal with the Montana Hospital Association's home care division. "They are only willing to jump through so many hoops."

"Physicians, as a general rule, have not responded well to the requirement and the unrealistic expectations associated with increased documentation for them," observes Kim Foltz with Iowa Alliance in Home Care. "We've heard verbally from physicians that they will be less likely to refer to home care because of the requirements."

The result: "We're concerned, and believe strongly, this will result in more avoidable hospitalizations and ER visits," Foltz adds.

The access problem will be exacerbated by the policy many HHAs are adopting, which is to not admit a patient without the FFE physician documentation complete, or at least the FFE visit.

"Most agencies are ... making sure they get all of the necessary face-to-face forms upfront and not risk trying to track these down later, which could result in non-compliance and/or non-payment," relates Keith Ballenger with Adventist Home Care Services in Silver Spring, Md.

"The majority of agencies have stated that a patient will not be accepted without a documented encounter prior to the HHA start of care date," agrees Kathleen Anderson with the Ohio Council for Home Care and Hospice.

This could be a big problem for patients who have no physician. "We just finished a transitions of care study with Virginia Commonwealth University, Medical College of Virginia, Department of Gerontology, which indicated that 10 percent of acute care patients that were referred to home care have no physician," reveals Marcia Tetterton with the Virginia Association for Home Care & Hospice. "Given this fact, there is no question it will limit access to home care and it potentially could be significant."

The problem may be particularly sticky for patients who go out of area for treatment, says Beth Putnam with Central Montana Medical Center's home care division in Lewiston.

For example: In a common scenario, "patient goes to Billings for hip surgery, we get orders for home health PT and SN for protimes from the doc at the nursing home the patient went to in Billings after surgery," Putnam relates. "That doc won't sign POC, ortho doesn't want to because he's not ordering the Coumadin, local doc has not seen patient in a year."

The result is "the referral source thinks I am being a pain trying to find out who will sign my POC and face-to-face," Putnam says.

And don't forget the impact this has on the beneficiary, points out Brad Garpestad of Spectrum Medical Inc. in Great Falls, Mont. Benes have "difficulties getting to their primary care provider, which usually involves coordinating time with a friend or family member and the taxing and difficult effort that beneficiaries exert in getting to their physician."