Home Health & Hospice Week

Many providers fear that some physicians will stop referring home care patients, based on comments they've received from docs (see related story, p 59). But even if you can manage to get referring physicians to agree to provide the face-to-face encounter and related documentation, you have a whole new set of challenges.

First, you need to set up internal processes to keep track of the documentation and make sure it comes in on time. Then, you need to make sure the content of the FFE documentation will pass muster.

Sometimes agencies aren't sure what will work and what won't, or when a FFE is needed or by whom. HHAs may have a grasp of the FFE basics, but "are having questions about specific scenarios that may not have a black and white answer," notes Doris Visaya with the Home Care Association of Washington.

The bottom line: "The FFE is a cumbersome, unwelcome, and unnecessary method to address fraud and abuse," blasts Casey Blumenthal with the Montana Hospital Association's home care division. "As usual, it feels like all providers are being punished for the sins of a few with yet another unfunded and poorly designed regulation, whose impact has been severely underestimated by those who made it."