Home Health & Hospice Week

F2F form no longer cuts it.

The pre-claim review demonstration doesn’t impose any new requirements on home health agencies, but it does emphasize existing ones — particularly the face-to-face physician encounter mandate.

The skyrocketing Medicare payment error rate for home health has been largely due to F2F. The improper payment rate calculated by the Comprehensive Error Rate Testing program increased from 17.3 percent in 2013 to 51.4 percent in 2014 and is projected to increase to 59 percent for 2015, note HHH Medicare Administrative Contractors Palmetto GBA and CGS in a PCR educational presentation.

“Many providers still don’t understand the requirements that took effect Jan. 1, 2015,” says Chicago-based regulatory consultant Rebecca Friedman Zuber. “They still think a face-to-face form will work.”

Musts: Many agencies “really don’t understand what is required for the certification statement, and they don’t understand that they have to have the actual clinical note from the physician,” Friedman Zuber continues. CMS had hoped the Probe & Educate review campaign would improve F2F compliance, and it “may have helped with that somewhat,” Friedman Zuber allows. “But the inconsistency in the reviewers has allowed [agencies] to maintain skepticism” about the F2F requirements that took effect last year.

In its PCR education session, Palmetto emphasizes that agencies must submit an actual physician visit note with the request (see box, p. 206). The Centers for Medicare & Medicaid Services has specified five elements the note must contain (see box, this page). If agencies fail to include the physician visit note, they’ll face non-affirmation and either receive a claim denial or have to go through PCR all over again — with a longer 20-day response time for the MAC.

The same goes for the medical records proving homebound and medical necessity — they must be from the physician.

Remember: Medicare does allow your documentation to help support F2F findings, when the physician signs it into her record (see Eli’s HCW, Vol. XXV, No. 11). But beware of when your records and the physician records conflict, Friedman Zuber warns. “If your assessment contradicts the physician’s encounter note, it could be a problem,” she says.

Note: See a CGS fact sheet on F2F online at www.cgsmedicare.com/hhh/education/materials/pdf/FTF.pdf.