Home Health & Hospice Week

Use this recommended strategy to reduce physician burden.

Home health agencies are weary from shouldering yet another face-to-face encounter burden with the requirements that took effect Jan. 1. But there are a few upsides to the new rules.

Under the F2F requirements in place for episodes that began before Jan. 1, certifying physicians had to sign the plan of care and the face-to-face documentation including the physician narrative. Now the narrative is gone for all but those patients requiring management and evaluation, Centers for Medicare & Medicaid Services officials noted in a December National Provider Call, “Certifying Pa-tients for the Medicare Home Health Benefit.”

Back To 1 Signature

How home health agencies format their POC and F2F documentation is totally up to them, as long as they meet the content requirements set out in regulation, noted CMS’s Jill Nicolaisen in the call. In response to the question, “is it necessary to have a separate certification form signed by a physician or can the certification requirement be built into the plan of care or physician orders?” Nicolaisen replied, “CMS does not require a specific form or format for the certification and/or the plan of care as long as the certification requirements and the plan of care requirements are otherwise met.”

“As long as the certification contains all of the elements … and also indicates the date that the encounter occurred, there doesn’t need to be a narrative anymore,” said CMS’s Hillary Loeffler in re-sponse to a caller question. “So if you can include that all on one plan of care form or one certification form, we don’t necessarily need a separate face-to-face document.”

Those five elements include:

1. Need for the skilled services;
2. Homebound status;

The certifying physician’s and/or the acute/ post-acute care facility’s medical record for the patient must contain the actual clinical note for the face-to-face encounter visit that demonstrates that the encounter:

3. Occurred within the required timeframe,
4. Was related to the primary reason the patient requires home health services; and
5. Was performed by an allowed provider.

Important: It’s the doc’s or facility’s clinical note that must show the last three, not your documentation (see related story, p. 18).

Combining the POC and F2F is the strategy that the Illinois Home Care & Hospice Council is suggesting to its members, notes Chicago-based regulatory consultant Rebecca Friedman Zuber. “IHHC is recommending that our members use an addendum to the plan of care to share information from the assessment that will support the physician’s certification of homebound status and need for skilled care,” Zuber says. “This would mean that no extra signature would be required since the physician must sign the plan of care anyway.”

Do this: “The trick will be to insure that their staff file a signed copy in the physician’s record,” Zuber notes of the POC with the addendum.

Hospital Notes Stand On Their Own

The interaction between the hospital physician conducting the F2F visit and the community physician certifying the patient for home care may undergo some streamlining.

When the hospitalist conducts the F2F encounter, his note doesn’t need to be cosigned by the certifying physician, Loeffler indicated in the call. “We’ll be looking for the actual clinical note,” she told a caller in the question-and-answer portion of the call. “And that does not need to be cosigned, it stands on its own.”

“That’s great news,” said the caller.

No Extra Signatures For NPPs

As long as the certifying physician signs the cert, he doesn’t also need to sign the clinical note for the F2F encounter in cases where a qualifying non-physician practitioner conducts the visit.

“The certifying physician does not need to cosign the clinical note from a face-to-face encoun-ter performed by an allowed nonphysician practitioner,” Nicolaisen said. “In order for the certification of eligibility to be considered complete, the certification requirement detailed in the presentation today [the five elements above] must be complete, and the certification must be signed and dated by the certifying physician.” 

Note: The 2015 HH PPS final rule containing the new requirements, published in the Nov. 6, 2014 Federal Register, is at https://federalregister.gov/a/2014-26057.