Home Health & Hospice Week

Docs include de facto narrative in latest version.

Home health agencies might not be any better off with the physician face-to-face encounter requirement, judging by the final version of the F2F form issued this month.

After working on the voluntary physician F2F encounter form for more than a year, the Centers for Medicare & Medicaid Services has submitted the final version to the Office of Management and Budget for approval. The final form, which is a “progress note” for the physician to complete, includes many of the changes CMS made through multiple versions of the form.

Better: An early version of the form had a five-page patient evaluation section for the physician to fill out. Then CMS whittled it down to about a page and a half. Now, that length is back up to nearly three pages, thanks to fill-in-the-blank sections for the physician to specify the patient needs and homebound status. But at least the physical assessment is largely checkboxes.

Worse: The fill-in-the-blank sections to specify the reasons for skilled services and homebound are “similar to the old F2F encounter document agencies used when a narrative was required,” notes the National Association for Home Care & Hospice. “Although CMS eliminated the narrative from the F2F encounter regulation, the template format essentially adds it back into the process for physicians certifying home health patients,” NAHC criticizes. “Therefore, NAHC has reservations about its usefulness as a tool that will assist physicians in documenting eligibility criteria for Medicare home health services.”

Also worse: The final version includes a box to check if the physician conducting the F2F encounter will not be following the patient’s care after discharge. Then the form directs the doc, “If the patient requiring home health services is being discharged to home from a hospital/acute care facility, and the discharging physician will not be following the patient after discharge, then please identify the community physician who will be taking over care for the patient.” The form includes space for the community physician’s name, address and phone.

“The statement is misleading since [the] acute/post-cute care physician only needs to identify the community physician who will be following the patient if the acute/post-acute care physician is the certifying physician,” NAHC points out. “If the acute/post-acute care physician is not the certifying physician, there is no need to identify the community physician.”

Docs Weary Of F2F Burden

Expect to hear further complaints from your physicians about the F2F requirement, says consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C. “There will continue to be physicians who will not refer to home care because they do not want to be bothered with the necessary ‘paperwork,’” Laff laments. This form won’t really help with that.

NAHC “has concerns that the template will not be well received by physicians,” it agrees.

But the form may help with physicians who are leery of turning over their patient records for review to support the HHA claim, Laff suggests. “Stress to the physician that if he/she completes the form and incorporates this into his patient records, audits of his/her records will not be likely to occur to substantiate [the] home care provided,” she recommends.

That’s reason enough to use the form, even though it’s not perfect, she tells Eli.

Teach: Just be sure to educate physicians and their staff members on what’s needed to complete the form correctly. Teach them about the qualifying criteria and documentation of how the patient meets that criteria, Laff urges. 

“A high percentage [of physicians] will continue to complete it incorrectly,” Laff says of the form. 

NAHC fears the form “will not be completed to the medical reviewers’ satisfaction,” it says. But education on your part should improve accuracy.

You can get some help in educating your physician partners from the Medicare Administra-tive Contractors, who have stepped up their F2F education efforts.

For example: MAC National Government Services is publicizing its series of F2F educational sessions for docs and facilities, which will run from fall into early winter.

Note: See the form at www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10564.html.