Home Health & Hospice Week

Agencies can fight off denials by using form in an unexpected way.

Check out the newest version of Medicare’s voluntary “Clinical Template” for physician face-to face encounters to see what medical reviewers are looking for in your ADR responses.

The Centers for Medicare & Medicaid Services issued its last version of the form last summer (see Eli’s HCW, Vol. XXIV, No. 30). CMS has now issued another slightly changed version of the form and the Office of Management and Budget is taking comments on it until Jan. 27, according to a notice in the Dec. 28, 2015, Federal Register.

Biggest change: CMS cut a paragraph that asked the provider furnishing the F2F to identify the community physician who will be taking over care for the patient, if the patient was discharged from a facility.

The National Association for Home Care & Hospice cheers the revision. The facility physician should have to identify the community physician following the patient only when the facility physician certifies the patient for home care, not merely when she furnishes the F2F visit, NAHC had contended. CMS appears to have heeded industry comments on this topic in the last form.

Another change: The new version of the form offers a “Plan/Orders” section separate from a “Plan for Home Health Services” section detailing skilled nursing, therapy and other service requirements.

It’s always a good idea to use the current CMS form, says attorney Amy Fehn with the Law Offices of Fehn, Robichaud & Colagiovanni in Troy, Mich. But since the form is voluntary and the changes are nonsubstantive, “then I don’t think it would be a problem if they are still using the older form,” Fehn judges.

Pro: Fehn recommends using the template if you can get your referring physicians to go for it. “Use of the form will make it easier for auditors to see the homebound and medical necessity elements in a format in which they are accustomed,” Fehn tells Eli. “Any time that you can make it easier for reviewers to find the relevant information, it is better.”

However, many agencies do not expect their referring physicians to be on board with the idea (see related story, p. 18).

Another use: This template can give agencies a good teaching tool both for themselves and for physicians, suggests attorney Robert Markette Jr. with Hall Render in Indianapolis. HHAs that are already undergoing Probe & Educate claims reviews focusing on F2F report that medical reviewers seem to be looking for the information CMS contains in its form.

HHAs that provide the homebound and skilled service information contained in the form to their physicians, in documentation to be signed into the doc’s clinical record, can use the form as a guideline for that document. HHAs that want to see the information furnished by their physicians in their medical records can use the template to show those physicians what reviewers are looking for.

Warning: In its instructions for filling out the form, CMS emphasizes that “The Home Health agency cannot complete this form and send to the physician for his signature.”

More changes ahead: Don’t expect this version of the form to be final, Fehn adds. “I would not be surprised if … [CMS] would continue to tweak it based on comments from the industry,” she says.

Note: See the new form at www.reginfo.gov/public/do/PRAViewIC?ref_nbr=201512-0938-012&icID=219423. Instructions for submitting comments are at www.gpo.gov/fdsys/pkg/FR-2015-12-28/pdf/2015-32435.pdf.