Home Health & Hospice Week

Question: Regarding the face-to-face physician encounter requirement for home care patients, "I thought the hospitalist could complete the F2F upon discharge and the certifying physician could sign the [plan of care] already. How does this proposal [in the 2012 prospective payment system proposed rule] change the current process? Does this change allow the hospitalist to contact the certifying physician to communicate their findings but then the hospitalist does not have to complete the F2F document?"

-- Iowa Reader

Answer: In the 2011 final PPS rule, the Centers for Medicare & Medicaid Services said that the hospital physician could perform the F2F encounter, but also had to furnish the F2F documentation, certify the patient for home care eligibility, and initiate orders. The community physician would merely sign the plan of care after the hospitalist handed the patient off, according to the final rule published in the Nov. 17, 2010 Federal Register.

Now, CMS is proposing to allow the hospital physician to conduct the F2F visit, but then just communicate his clinical findings to the community physician. The community physician will then fill out the F2F documentation, certify the patient, initiate orders, and sign the POC.

In other words, "the attending acute or post-acute physician must communicate the clinical findings of the face-to-face encounters with the patient to the certifying physician, so that the certifying physician could document the face-to-face encounter accordingly, as part of the signed certification," CMS says in the 2012 PPS proposed rule published in the July 12 Federal Register. The change is proposed to take place Jan. 1, but must be finalized in the final PPS rule due around October.