Home Health & Hospice Week

Compliance:

Physicians Balk At Face To Face Burden

Home care providers question CMS's education effort for docs on the new requirement.

The new face to face encounter (FFE) requirement comes with a lot of headaches, and the biggest one may be getting physicians on board for the mandate.

Case in point: Hospitals are getting a myriad of forms for FFEs from home health agencies, said a hospital caller in the Jan. 19 Centers for Medicare & Medicaid Services Open Door Forum for home care providers. Hospitals don't necessarily feel it's their job "to get this done," said the caller who said she was from a Colorado hospital. And hospitals are having a hard time locating reliable information about the requirement.

"It's not the hospital's responsibility, it is the physician who certifies eligibility for the home health benefit," maintained CMS's Lori Anderson in the call. But that amounts to the same thing, the caller said.

CMS has launched a broad physician educationeffort, Anderson told another caller. The agency has targeted physician professional associations and other physician groups with fact sheets, an MLN Matters article, and the questions-and-answers CMS has issued on the topic. "By and large I think that we're doing about as comprehensive of an outreach effort as can be done," Anderson told attendees.

Anderson asked the industry for any additional ideas for where to send educational information for physicians.

One suggestion: Physician Part B carrier Trailblazer doesn't have information about the FFE on its website, noted Rachel Hammond with the Texas Association for Home Care & Hospice. CMS will make sure the information gets on there, Anderson assured listeners.

Hammond also raised the idea of establishing a specific e-mail box for FFE questions. "We are still getting a lot of questions that are not addressed in the Q&A," Hammond said in the call.

Deadline: CMS reiterated that it won't be enforcing the FFE provisions for home health agencies and hospices until April. But the agency expects home care providers and physicians to be working together now to establish FFE processes by the deadline, Anderson stressed.

"Beginning with the second quarter, CMS will expect home health agencies and hospices to have fully established such internal processes and have appropriate documentation," Anderson said.

Resource: CMS has posted the FFE Q&As on the home health center page at www.cms.gov/center/hha.asp, because most of the questions it has received related to the HHA FFE, Anderson said.

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