Home Health & Hospice Week

MAC Tip: Bypass subpar physician F2F statements by requesting the doc’s own notes.

CMS has changed its tune on whether check boxes are OK for face-to-face physician en-counter documentation, but you still have to be careful with the tool, contractors warn. That’s one of the many pieces of advice that HHH Medicare Admini-strative Contractors are giving home health agencies about F2F documentation requirements in new educational articles on the matter.

"An increase in denials of home health claims is occurring because the face-to-face encounter document submitted includes insufficient information," HHH MAC NHIC says in a recently posted article on the requirement. "The root cause of the majority of these costly denials can be attributed to the submission of an insufficient narrative on the face-to-face encounter document. A description of why the patient needs skilled nursing or therapy services and a description supporting the patient’s homebound status are often missing."

Use this advice from MACs NHIC, Palmet-to GBA, and CGS to keep your claims from getting denied for F2F deficiencies:

1. Ask for doc notes. F2F narratives supplied by physicians are often lacking, CGS allows. Smart HHAs will bypass the anemic documentation supplied by docs and go straight to the source — the physician’s documentation for his own charts.

"To assist home health agencies in avoiding denials for the FTF encounter documentation, CGS recommends that the agencies request the actual FTF encounter documentation that the physician or non-physician practitioner (NPP) completed when the patient’s FTF visit was performed," the MAC says in a recently posted article on the topic. "This could include progress notes, visit notes, and/or the history and physical (H&P)." The agency then simply must title it and have the certifying physician sign it.

Caveat: "If an NPP performs the FTF visit, the physician that signed the FTF document would also need to sign the actual visit notes from the NPP, in order for CGS to accept them," CGS explains.

Requesting these records could actually make life easier for the doc by eliminating another paper to fill out. "If the required narratives regarding skilled need and homebound status are contained in the progress notes/H&P, there would not be a need for an additional FTF form," CGS offers.

2. Check boxes are OK, but preprinted statements are not. "Some face-to-face encounter forms have a preprinted statement regarding the homebound status which is unacceptable," NHIC says in a recent educational article. "A preprinted statement that copies part of the Centers for Medicare & Medicaid Services (CMS) guidelines does not meet this criterion. The physician’s assessment of the patient’s homebound status is required."

Question: In Palmetto’s July 16 Ask the Contractor Teleconference, an agency asked whether it’s "acceptable on different parts of the face to face to have check boxes to help the physician fill it out correctly?"

Answer: "There is not an issue or a regulation that says you cannot have check boxes," Palmetto admits. "However … many times because of the check boxes, the provider will not add as much detail to that face to face documentation as they would if they did not have a check box." Ultimately, "we would just caution you that using those sometimes can limit the amount of information you get and you will want to make sure that your documentation meets the Medicare requirements regardless of whether there are check boxes included or not," the MAC says.

3. Beware hospitalist narrative. Just because a hospital or skilled nursing facility physician provides a narrative, doesn’t mean it’s sufficient. "The community physician must ensure all needed information is included" in the other doc’s narrative, NHIC advises. "Sometimes information regarding the homebound status or information about the patient’s need for skilled nursing or therapy is missing," the MAC cautions.

Tip: "The community physician may add [homebound and/or skilled need] information to the document," NHIC explains. "The community phy-sician can indicate that this is the documentation of the face-to-face encounter by signing and dating the document."

Note: See the articles containing more F2F advice, documentation examples, do’s and don’ts, and links to further resources at www.medicarenhic.com/providers/articles/F2FQualityChecklist.pdf,www.medicarenhic.com/providers/articles/HHFacetoFaceRev022813.pdf and www.cgsmedicare.com/hhh/pubs/news/2013/0713/cope22734.html