Home Health & Hospice Week

Pop quiz: What’s the one scenario that allows different practitioners to complete the face-to-face encounter and the home health certification?

Face-to-face encounter denials shoot down many home health claims. Make sure you’re armed with everything you need to fly high above the FTF denial fray.

Protecting your agency against FTF denials starts with understanding the requirement completely. In a new medical review results report, HHH Medicare Administrative Contractor Palmetto GBA points out than an FTF encounter must:

• occur no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care;
• be related to the primary reason the patient requires home health services; and
• be performed by a physician or allowed Non-Physician Practitioner.

Weigh these tips when making sure your claims are denial-proof:

1. Examine the date carefully. What may seem like a simple part of the requirement can actually get quite tricky. The 90-days-before-to-30-days-after mark can’t be documented by the HHA, HHH MAC CGS points out in its FTF Encounters for Home Health Certification Quick Resource Tool.

Instead: There must be “documentation by the certifying practitioner of the FTF encounter date,” CGS emphasizes. In other words, the FTF documentation must include that date as documented by the doc or allowed NPP.

Also, “if the FTF encounter occurred within 90 days of the [start of care] but is not related to the primary reason for home health, the NPP or certifying physician must have a FTF encounter within 30 days after the SOC,” CGS tells agencies in the tool.

2. Double-check the primary reason. “The FTF encounter must be related to the primary reason for the home care admission,” CGS says in a FTF coverage guideline article (emphasis original).

Elaboration: HHAs have run into varying interpre­tations of what exactly this means. Palmetto recently offered this guidance on the matter in a Home Health and Hospice Coalition meeting question-and-answer set: “The clinical encounter note must be related to the primary reason for home health. It doesn’t have to be the main focus, but it does need to be addressed (more than just being on a list of diagnoses).”

3. Screen for the correct physician or NPP. Medicare allows four categories of physicians or NPPs to perform the FTF encounter (see box, this page). It can get especially confusing when the FTF physician is not the certifying physician.

“Keep in mind that only one situation allows different allowed practitioners to complete the face-to-face encounter and the home health certification requirements,” Osentoski points out. “This is when the patient is admitted to home health ‘directly after discharge from an acute/post-acute care setting’ and the allowed practitioner who cared for the patient in that setting will not be the home health care allowed practitioner,” he explains.

“Do not confuse this with the ability of non-physician practitioners to complete the encounter,” he cautions. “Here it’s the certification requirements that need to be met.”

Plus: “The entity performing the FTF encounter cannot be employed by or have a financial relationship with the home health agency” under Stark Law governing physician self-referrals, CGS notes in its FTF Encounters for Home Health Certification Quick Resource Tool.

4. Telehealth encounters remain OK — for now. “There is no requirement mandating where the FTF encounter takes place,” CGS highlights in its FTF certification Quick Resource Tool. “Medicare-eligible telehealth visits are allowed,” the MAC confirms.

Keep an eye on legislative and regulatory developments to see whether telehealth encounters will still count for FTF after the COVID-19 public health emergency expires (see related story, p. 219).

5. Go to the source. “Read the documents used to meet the FTF encounter requirements,” Osentoski advises. “Nothing substitutes for a review of the actual note,” he stresses. “This remains the single best method to ensure the three components of encounter note, primary diagnosis, and plan of care are aligned,” he offers.

“The certifying physician and/or acute/post-acute care facility medical records must include the actual clinical note for the FTF encounter visit,” CGS lays out in its Quick Resource Tool. The note must demonstrate that the encounter occurred within the required timeframe; was related to the primary reason the patient requires home health services; and was performed by an allowed provider type, the MAC reviews.

The required FTF encounter information “can be found most often in, but is not limited to, the following examples,” Palmetto offers in its post. “Discharge Summary; Progress Note; Progress Note and Problem List; or Discharge Summary and Comprehensive Assessment.”

Warning: “A diagnosis code alone is not sufficient documentation to support homebound status or the need for skilled care,” CGS stresses in its fact sheet. (See good and bad FTF examples, p. 216.)

6. Nail the timing. If you receive an FTF-based denial, you can’t just go back and fix the problem, the MACs stress. “It’s the home health agency’s responsibility to … ensure the physician’s documentation is complete before billing,” CGS instructs in its fact sheet (emphasis added).