Home Health & Hospice Week

Rule commenters note added FTEs to deal with the F2F burden.

The face-to-face physician encounter is draining resources from home health agencies, and they aren’t afraid to tell the feds about it.

Multiple commenters on the 2015 home health prospective payment system proposed rule pointed out the extra cost burden to them under F2F. “In a time when home care needs to be reducing expenses we are adding FTEs to review face-to-face encounters for clinical accuracy and chase these documents,” Melissa Mahaney in Kentucky tells the Centers for Medicare & Medicaid Services in her letter.

“Our agency has been forced to add a .5 FTE employee just to follow up on the F2F documentation in order to be in compliance,” says Victoria Testa from Pennsylvania in her comment letter.

“The physician face-to-face documentation requirement is clearly the most difficult regulatory requirement that I have encountered in over 20 years in home health compliance oversight,” says a rep from Partners in Home Care in Montana. “Despite a very aggressive physician education campaign, we are returning approximately half of our face-to-face forms for insufficient documentation. In addition, we have added at least 1.5 full-time equivalents for tracking, auditing, physician education, and other face-to-face processes,” says the agency with an average census of 120 patients.

“This is the most onerous requirement I’ve encountered in all my years in HH,” says a rep from Genesis VNA in Iowa. The agency “added two full time FTEs to manage and it’s still a struggle. We can’t manage physician behavior.”

“CMS has not taught physicians how to properly fill out a face-to-face to begin with,” criticizes one Colorado agency rep in a comment letter. “HHAs are constantly educating and returning face-to-face documentation to physicians so they can give the proper verbiage and narrative requirements for this rule. It is a huge undertaking requiring a lot of man hours.”

Bottom line: “The intent of the ACA F2F requirement is completely misinterpreted by CMS,” charges the Arkansas Department of Health in its comment letter. “CMS has missed the intent of the F2F requirement, which was that patients have a face-to-face encounter with a doctor who recognized the need for home health. Not the technicality of how this encounter was documented.”