Home Health & Hospice Week

Three sentences is all it takes to get into compliance — but they must be the right three sentences.

Are your docs at a loss when it comes to crafting the face-to-face encounter narrative? That could spell big trouble for your cash flow.

The Centers for Medicare & Medicaid Services “will consider the face-to-face documentation incomplete without this narrative,” the HHS Office of Inspector General stresses in its recent report on F2F. “Because the face-to-face requirement is a Medicare condition of payment, CMS will deny the payment for the initial and all subsequent episodes of care.”

Boost your physician education efforts’ success by furnishing narrative examples as guidance. This is the briefest narrative example CMS offers which covers both homebound and skilled service:

• The patient is temporarily homebound secondary to status post total knee replacement and currently walker dependent with painful ambulation. PT [physical therapy] is needed to restore the ability to walk without support. Short-term skilled nursing is needed to monitor for signs of decomposition or adverse events from the new COPD [chronic obstructive pulmonary disease] medical regimen. (Source: February 2013 CMS question-and-answer #10480.)

Here’s a slightly longer CMS narrative example that fulfills both the homebound and skilled need elements, from MLN Matters article SE1405 issued earlier this year:

• Ms. Jane Doe is a 99 year old female hospitalized with congestive heart failure (CHF) exacerbation (she has co-morbid asthma and low vision). She is going home and needs skilled nursing due to a new medication regimen and high potential for hospital readmission. She also needs in-home PT for strength training due to deconditioning during CHF exacerbation and safety assessment because she is at risk for falls. She is unable to leave the house without a walker.

In the MLN Matters article, CMS offers these examples for the homebound portion of the narrative:

• Ambulates limited distance of 125’ with assistance of a walker due to acute stroke.
• Poor endurance, shortness of breath with minimal ambulation due to congestive heart failure (CHF) and needs assistance to leave the home.
• Deteriorating mental status, unable to leave home unsupervised.
• Frequent seizure activity, requires supervision/assistance of another person. 

Note: For more tips on how docs should complete the narrative, see the MLN Matters article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1405.pdf. A link to CMS’s F2F Q&As is at www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html — scroll down to the “Home Health Face-to-Face” section in the “Spotlights” box.