Home Health & Hospice Week

HHS insists F2F changes will help.

Historically high profit margins aren’t the only problem dogging home health agencies. In its 2015 Annual Financial Report, the Department of Health and Human Services notes that the already staggering improper payment rate of 51 percent for home health agencies in 2014 rose to an even more shocking 59 percent rate last year.

 In comparison: Medicare’s overall improper payment rate for fee for service is 11 percent.

“The primary causes of improper payments are insufficient documentation and medical necessity errors. Insufficient documentation was particularly prevalent for home health claims,” HHS says in the report released in November. The rise in HHAs’ rate is “due to the documentation requirements to support the medical necessity of the services.” HHS maintains that these activities will help curb the ridiculously high rate:

• The Centers for Medicare & Medicaid Services eliminated the physician narrative for the face-to-face physician encounter. “Now reviewers can consider all entries in the medical record as supporting documentation when determining medical necessity,” HHS praises.

“Clarifying the face-to-face requirements will lead to a decrease in these errors and improve provider compliance with regulatory requirements, while continuing to strengthen the integrity of the Medicare programs,” HHS believes.

However: HHAs say the new requirement may be even harder to fulfill than the old one (see Eli’s HCW, Vol. XXIII, No. 43).

• CMS created “voluntary draft paper and electronic clinical templates for ordering physicians and ordering hospitals to serve as progress notes and discharge summaries. These templates are currently in the clearance process,” HHS says. “The templates will help physicians and hospital staff capture the information needed to complete the face-to-face encounter documentation and will become part of the medical record upon completion.”

However: Industry sources say the forms are too long, duplicative of the still-required physician note, and too similar to the old physician narrative to make compliance easier (see Eli’s HCW, Vol. XXIV, No. 30).

• HHH Medicare Administrative Contractors initiated “Probe & Educate” reviews based on F2F in October. The “Probe and Educate strategy [is] designed to help HHAs understand the new patient certification requirements,” HHS maintains.

However: The jury is still out on this claim, but industry veterans fear the P&E procedures could lead to agencies being placed on perpetual prepayment medical review (see Eli’s HCW, Vol. XXIV, No. 42).

Note: See the full report at www.hhs.gov/afr/fy-2015-hhs-agency-financial-report.pdf.