Home Health & Hospice Week

Agencies seek answers as the new F2F implementation date nears.

With Jan. 1 right around the corner, do you know how to furnish information to the certifying physician that may save your claim from denial?

In its 2015 HH PPS final rule, the Centers for Medicare & Medicaid Services spells out that agencies may submit information to the doc to help prove home care eligibility (see story, p. 338). However, it includes no details on exactly what is acceptable and will pass medical review scrutiny.

“We don’t know what they mean by ‘review and sign-off,’” notes Chicago-based regulatory consultant Rebecca Friedman Zuber.

Clue: In the Nov. 12 Open Door Forum for home care providers, CMS’s Hilary Loeffler clarified that the certifying physician “will have to adopt [the information you furnish] into his or her medical record, meaning they agree with what you’ve written, and they are signing it and dating it into their medical record.”

The rule language seems to say that “as the MD ‘agrees’ and signs off on the summary — it will fly,” expects clinical consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C.

Judy Adams with with Adams Home Care Consulting also thinks the rule says “that the physician can make the home health summary a part of their medical record by simply signing and dating the summary,” she tells Eli. “However, I expect CMS will come back and require the summary to be labeled as F2F.”

Wrinkle: “Most physicians are now on electronic records, so including a summary from the HHA may also be an issue related to incorporating into the electronic record,” Adams cautions. You’ll need to check with individual physician practices to see how that will work.

Another problem is that some physicians may be hesitant to sign off on your findings for liability reasons. Physicians’ “malpractice carriers may have some trouble with the potential for liability such an action would raise,” Zuber expects. “Unfortunately, this uncertainty is likely to contribute to more confusion and frustration down the road.”

Caution: And don’t assume that the adoption of your discharge summary will be enough to pass medical review, warns Patricia Jump with Acorn’s End Training & Consulting. “In many instances, the summary does not indicate homebound status and it may or may not have all of the orders for skilled services.”