Home Health & Hospice Week

Watch out: The feds say they will enforce the face to face encounter rule for home health agencies through medical review from Medicare contractors, as well as state surveys.

"This signifies more frequent and more indepth scrutiny of clinical records than ever before," says consultant Pam Warmack with Clinic Connections in Ruston, La. That's "always disconcerting to home care providers."

Agencies may have a lot of difficulty obtaining FFE documentation that satisfies the requirement, Warmack worries.

The Centers for Medicare & Medicaid Services says it won't allow physicians to use generic checkbox-type documentation or to merely sign template statements generated by the agency. "We believe that were we to allow the HHA to craft standard language which the physician would then simply sign, we would not achieve the sort of physician involvement in the eligibility determination and care plan which was the Congress' intent," CMS says in the prospective payment system final rule published in the Nov. 17 Federal Register. "As such, we believe that if a HHA were to develop standardized encounter language to be signed by the physician, they would not be adhering to the statutory payment requirements that the 'physician document' the encounter."

But the rule appears to be silent on how much agencies can help physicians craft a patientspecific statement, Warmack observes. "Exactly how much involvement will the provider be allowed

in assisting the physician in preparing the required documentation?" she asks.