Home Health & Hospice Week

Face-To-Face:

Don't Hold Your Breath For F2F Changes

F2F poised to run HHAs out of business.

If you think absurdly high denial rates for the face-to-face Probe & Educate campaign will persuade CMS to relent on F2F requirements, think again.

With the F2F-based denials racking up under Medicare’s Probe & Educate initiative, some agencies hoped that the Centers for Medicare & Medicaid Services would back off on the more unreasonable parts of the new requirement.

Industry veterans find that outcome highly unlikely. “CMS is totally dug in here,” judges regulatory consultant Rebecca Friedman Zuber. “We have argued, cajoled, threatened, sued and more.”

“It is unlikely that CMS would revise the process based on the high denial rate,” agrees Sharon Litwin with 5 Star Consultants in Camdenton, Mo. “On the contrary CMS is getting the results they wish to obtain — reducing the cost of the home health benefit.”

It will take a successful lawsuit or legislative action to change F2F now, believes Judy Adams with Adams Home Care Consulting in Asheville, N.C.

And due to political conflicts, changing anything in the Affordable Care Act which contains the F2F encounter requirements (but not the documentation stipulations added by CMS) is nigh impossible, Friedman Zuber notes.

“CMS is simply not living in a realistic world in their expectations of home health providers,” says nurse consultant Pam Warmack with Clinic Connections in Ruston, La. “Until the F2F requirements hits the physicians in their own pocketbooks, nothing will change for us.”

The dire result: “Denial percentages as high as these are clearly indicating there is a major problem that will result in HHAs going out of business and patients going without needed services without some relief,” Adams predicts.

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