Home Health & Hospice Week

Not all is lost if you miss the encounter deadline.

With the new face-to-face encounter mandates in the 2013 Home Health Prospective Payment System final rule, some providers are bound to make mistakes. And if you find yourself in the unfortunate situation of committing a FTF encounter blunder, what should you do?

Scenario: You’re on day 31 following the patient’s start of care during an acute or post-acute inpatient stay. However, the physician has not yet performed the FTF encounter.

If the FTF encounter does not occur by day 30 after the SOC, you cannot bill the episode because you did not meet the Medicare benefit requirements, says M. Aaron Little with BKD. So you basically have two choices: discharge the patient or establish a new episode once the FTF encounter occurs.

Discharge: Get Ready To Forfeit Everything

Opting for discharging the patient will set into motion a series of reimbursement-destroying events. According to Little, here’s what could happen:

No FTF encounter by day 31 → Home Health Advance Beneficiary Notice issued → Patient discharged → OASIS deleted → Request for Anticipated Payment canceled → RAP payment recouped.

How To Make It Right

In many cases, you’re looking at the latter option to correct the FTF encounter mistake -- establishing a new episode. So after the FTF encounter actually occurs, you need to establish a new SOC date, Little states. You also need to establish a new plan of care with the new SOC and certification dates. The new SOC date should be the same as the first billable visit date by any covered service performed on or after 30 days prior to the FTF encounter date -- even if the OASIS assessment was not originally completed on the new SOC date.

The catch: All services performed prior to the new SOC date are not covered -- you cannot bill these services and get payment for them, Little warns. Also, you must delete all OASIS assessments completed prior to the new SOC date.

Then, the OASIS assessment originally completed closest to the new SOC date would form the basis of the new SOC OASIS assessment, Little says. "Even if there was not actually an OASIS assessment completed on that date, you’re going to have to go ahead and do a late assessment to account for this new start of care." And with this new SOC assessment, you can’t create any new scoring or new OASIS responses.

Update -- Don’t Copy -- These OASIS Items

Although you may do a good deal of copying over your OASIS information when you need to establish a new SOC, beware that you can’t copy every item from the prior assessments. According to Little, you must update certain key OASIS items; these include:

• M0030 -- update for the new SOC date;

• M0090 -- update for the actual date that the new assessment is generated, which would be sometime on or after the FTF encounter date;

• M0102 -- code the date physician ordered SOC as "NA";

• M0104 -- code the date of referral as the day prior to the new SOC date;

• M0110 -- update for any differences in episode timing; and

• M2200 -- update to reflect actual/estimated therapy utilization in the new episode period.

Lesson learned: According to Little, here’s what your process would look like if you opt to establish a new SOC date:

Late FTF encounter occurs after day 30 → New SOC established → OASIS prior to new SOC deleted → New OASIS completed → New POC completed → RAP for episode prior to new SOC canceled → RAP payment recouped → New RAP & final claim billed with new SOC.