Home Health & Hospice Week

These 3 items must be present in the clinical note or you won’t get paid.

At first, it looked as though compliance with the new face-to-face requirement could be simple — the certifying physician could just sign off on home health agency documentation supporting the eligibility, incorporating the HHA info into his own record.

But now it looks as though it won’t be that easy, judging from information the Centers for Medicare & Medicaid Services disseminated in a December National Provider Call, “Certifying Pa-tients for the Medicare Home Health Benefit.”

“The certifying physicians and/or the acute/ post-acute care facility’s medical record for the pa-tient must contain the actual clinical note for the face-to-face encounter visit,” explained CMS’s Hil-lary Loeffler in the call. “And the actual clinical note must demonstrate that the encounter occurred within the required timeframe, was related to the primary reason the patient requires home health services, and was performed by an allowed provider type.”

The good news is that the HHA information the doc incorporates into her record can still tackle the tough part — showing homebound status and skilled need. The documentation from the physician or from the facility may be “lacking,” noted CMS’s Randy Throndset in the call. Examples given in the call showed “some gaps … in what was there.” But information provided by the HHA can “fit with what the physician or facility was providing and … substantiate the eligibility,” he told an agency in the question-and-answer portion of the call.

While information from the HHA can be incorporated into the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient, keep in mind that the info “must be corroborated by other medical record entries and align with the time period in which services were rendered,” CMS stressed in the presentation.

Also, “the certifying physician must review and sign off on anything incorporated into the patient’s medical record that is used to support the certification of patient eligibility (that is, agree with the material by signing and dating the entry),” according to the slides for the call.

Loeffler underscored the fact that this rule aims to increase physician accountability related to home care. For the regulatory requirement that home care patients be “under the care of a physician … this means that the physician doesn’t just hand off the patient to the home health agency, but that the physician is actually acting as a supervisor of the patient’s care, and is, therefore, ultimately responsible for the patient,” she stressed.

CMS is “striving to increase physician accountability through this and other mechanisms, while they adhere to a rather dated notion of the role of the physician as the captain of the ship,” laments Chicago-based regulatory consultant Rebecca Friedman Zuber. “Physicians certainly play a critical role in the delivery of health care, but that role is changing, and CMS is out of touch with where the industry is headed,” Zuber tells Eli.

Other issues addressed in the call include:

• OASIS. The importance of your OASIS assessments will only increase under this rule. In one of the documentation examples, CMS Medical Officer Cindy Simpson illustrated how an OASIS document — and particularly information written in the document’s Comment section — could fill in the gaps of a physician record that doesn’t quite spell out the patient’s homebound status.

“We really value what you as clinicians working for the home health agencies do every day,” Simpson told call participants. “And we really do appreciate when you document what you are doing. That is quite helpful to us.”

• Resources. You can access the call’s audio recording, transcript, slides, and documentation ex-amples online at  http://www.cms.gov/Outreach-and-Education/Outreach/NPC/National-Provider-Calls-and-Events-Items/2014-12-16-Home-Health-Benefit.html .