Home Health & Hospice Week

You’ll have to look to lawmakers for relief.

Conference attendees gave CMS an earful about problems with the face-to-face requirement, but they may not have much to show for their efforts.

At the National Association for Home Care & Hospice March on Washington meeting April 4, Centers for Medicare & Medicaid Services Deputy Administrator Sean Cavanaugh offered a presentation about alternative payment models, but also took questions from the crowd. In response, he got some passionate feedback about the unworkable F2F physician encounter rule.

For example: Home health agencies have an incredibly difficult time obtaining the needed F2F documentation from physicians, Ed Schulte with Caregivers Home Health in Topeka, Kan., told Cavanaugh in the Q&A.

Referring physicians get very frustrated when an agency returns F2F documentation two or three times for correction, Schulte told Eli at the conference. In some ways, the physician narrative was easier because at least the information was all in one place instead of scattered throughout the physician record, he added.

Cavanaugh acknowledged the “disconnect” inherent in requiring supporting documentation from a provider other than the one getting paid for the service. That requirement has a “fundamental flaw” and leads to “huge documentation deficits,” as highlighted in the Comprehensive Error Rate Testing (CERT) reports that show a 59 percent error rate for HHA payments most recently (see Eli’s HCW, Vol. XXV, No. 1). Durable medical equipment suppliers face a similar problem, Cavanaugh noted.

However, CMS’s Program Integrity folks say there’s no way they can let HHAs or DME suppliers furnish that eligibility documentation themselves, because of the high rate of fraud in the industries, Cavanaugh said.

“We consider it a problem too,” Cavanaugh assured attendees in the Q&A. But the agency is still searching for a solution.

HHAs: CMS Created The F2F Problem

CMS officials are “scratching their heads, trying to figure out how to solve a problem they created,” protested NAHC’s Mary Carr in a separate session. “They don’t get that they are the problem.”

Due to this attitude, home care providers will most likely have to seek a legislative solution to the F2F problem, Carr noted.