Home Health & Hospice Week

Don’t duplicate face-to-face efforts unnecessarily.

Some eleventh-hour guidance from Medicare may ease your face-to-face encounter burden, at least somewhat.

In two new questions-and-answers, the Centers for Medicare & Medicaid Services indicates that physicians won’t have to reinvent the wheel when it comes to each piece of documentation a patient requires -- including the face-to-face encounter narrative, the home health plan of care, and the hospital discharge summary.

Because the F2F information is also “often present on the discharge summary and/or physician orders for home health services, the face to face encounter documentation narrative may satisfy multiple purposes,” CMS says in Q&A #10482. “A physician’s orders for home health services or an acute/postacute discharge summary can be used to satisfy the face-to-face documentation narrative, if they reflect the clinical condition of the patient as seen during the encounter, they are drafted by the physician or the physician’s support personnel, and they meet these requirements:

• documentation must be on the certification form itself or is an addendum to it, it must be separate and distinct.
• It must also include the following: 1) the patient’s name; 2) date of the encounter; 3) how the patient’s clinical condition as seen during the encounter supports homebound status and the need for skilled services; 4) the physician’s signature (original signature, a faxed copy, copy of original document with signature or electronic signature -- but not stamped signature); and 5) date of the physician’s signature.”

Just remember, the F2F addendum must be “separate and distinct,” CMS says in Q&A #10483. Being able to attach valid physician documentation to satisfy the narrative requirement “is a major clarification … that I believe will significantly ease the burden on both physicians and providers,” cheers consultant M. Aaron Little with BKD in Springfield, Mo.

Note: Order a recording of M. Aaron Little’s new Eli-sponsored F2F audioconference, “Warning Home Health & Hospice Providers: Face-to-Face Encounter Requirements Are In Effect,” at www.audioeducator.com/conference-conferencehome-health-face-to-face-encounter-230311 or call 1-866-458-2965.