Home Health & Hospice Week

Will checkboxes help or hinder your face-to-face compliance?

Your path to optimal face-to-face compliance may be paved with new F2F forms.

In a new report, the HHS Office of Inspector General urges the Centers for Medicare & Medicaid Services to issue a standardized form for physicians to use for their face-to-face encounter documentation (see related story, p. 122). But experts don’t expect CMS to issue such a form any time soon.

Instead, increase the chance that your claims will pass ever-expanding medical review with a form that elicits the best documentation from the physicians.

If you are starting from scratch, you may get an idea of what you’ll need from the National Association for Home Care & Hospice’s free sample form at www.nahc.org/advocacy-policy/home-care-regulatory-issues — scroll down to “Face to Face Encounter templates.” If you already have a form, you can see if it includes the elements NAHC recommends.

Tip: Take note of the required F2F elements as listed by HHH MAC CGS when designing or updating your form: a clear title to show it is a F2F encounter (which you may provide); the patient’s name; the date of the encounter; a description of the clinical findings during the encounter; an explanation of how the clinical findings support the patient’s homebound status; an explanation of how the clinical findings support the need for skilled home care; and the certifying physician’s dated signature (you may enter the date it’s received if it’s not dated by the physician).

More advice to consider when crafting or updating your F2F form:

• Weigh checkboxes carefully. CMS has given the green light to checkboxes on F2F forms in certain situations, but at least one HHH MAC told the OIG that it doesn’t accept checkbox forms. Another said it accepts checkboxes on a case-by-case basis.

Safe bet: If you’d like to use checkboxes on your F2F form, make sure there is also a place for the physician to write in the clinical findings supporting homebound and skilled need.

• Earn points with extra form items. CMS does not require these items in F2F documentation, but the OIG made a special point of praising documentation that included them: certifying physician’s National Provide Identifier number; physician’s printed name; name of nonphysician practitioner when she conducted the F2F encounter; HHA or hospital letterhead; and checkboxes for skilled services needed (i.e., skilled nursing, physical therapy, SLP, etc.). About 80 percent of forms the OIG reviewed had checkboxes for at least skilled nursing and PT.

Priority: Ten percent of face-to-face documents the OIG reviewed did not include a printed physician name. “Many signatures were illegible, and a printed name may be the only way to identify the certifying physician,” the OIG warns.

“Best practices should include a typed or stamped name under the signature,” recommends law firm Fehn Robichaud & Colagiovanni in Troy, Mich., in its analysis of the report.