Home Health & Hospice Week

You should keep checkboxes off the face-to-face documentation forms you give physicians to sign. F2F forms with lead-in phrases allow physicians to complete documentation in their own words, so CMS gives them a thumbs up.

But "a checkbox format does not seem to fit that," CMS says in response to a question from the National Association for Home Care & Hospice. "Checkboxes do not allow for the physician narrative describing the patient's clinical condition and how it supports the need for skilled services and homebound status," CMS says.

Meanwhile, the industry keeps up its advocacy campaign against the F2F requirement's burdens. Rep. Joe Courtney (D-Conn.) and 104 bipartisan cosigners sent CMS Administrator Donald Berwick a June 2 letter asking for changes to make the F2F requirement more manageable.

Among the changes requested are replacing the narrative with a simple certification that the encounter occurred. "This change falls completely within the purview of the law, which does not specify the documentation vehicle for the face-to-face encounter," the letter maintains.

The members of congress also ask CMS to allow non-physicians practitioners to conduct the encounter. Asimilar letter from a group of bipartisan senators went to CMS last month (see Eli's HCW, Vol. XX, No. 17, p. 135).

Rep. Courtney's letter and a related release are at http://courtney.house.gov.