Home Health & Hospice Week

Regulations:

F2F Clarifications To Ease Denials

If your claims were denied for these F2F errors, submit them for reopenings.

Now you've got it straight from the horse's mouth that you shouldn't receive denials for face-toface reasons when your patient's record fails to document the hand-off of care from the facility to the community physician.

HHH Medicare Administrative Contractor NHIC said in a recent provider meeting that the Centers for Medicare & Medicaid Services had instructed MACs to not issue denials when the hand-off isn't documented, in cases where the hospital physician signs the F2F documentation and the  community physician signs the plan of care (see Eli's HCW, Vol. XX, No. 43, p. 343). Now CMS has confirmed that information in a Dec. 9 e-mail to providers.

"It has come to our attention that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient," CMS says in the e-mail. "CMS has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician."

Another clarification: CMS also makes clear that it's OK for the community physician to sign the 485 form while the acute or post-acute facility physician signs a F2F addendum to that form.

Do this: Medicare contractors won't automatically give you money for claims they've erroneously denied for F2F reasons. HHAs must submit a request for reopening of such claims, CMS instructs in the e-mail message. Then MACs should "reopen and determine if face-to-face requirements have been met, due to their meeting the criteria," CMS says.

Full review: "However, a determination that face-to-face requirements have been met would not result in an automatic pay of the claim," CMS cautions. "Contractors must subsequently perform a complete and full review to determine if payment should be made."

Note: For a copy of CMS's e-mail message the outlines acceptable F2F scenarios that have previously been denied, e-mail editor Rebecca Johnson at rebeccaj@eliresearch.com with "F2F Denials" in the subject line.

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