Home Health & Hospice Week

Work on your physician relationships ASAP.

Face-to-face physician encounter requirements often torpedo claims, but you can keep your reimbursement afloat by following this expert advice under the new F2F physician documentation requirements:

1. Educate your staff. “The best preparation is repeated training for clinicians,” recommends Patricia Jump with Acorn’s End Training & Consulting in Rice Lake, Wis. “Providing examples and scenarios is helpful for the adult learner.”

You can incorporate emerging developments into your repeated training sessions as time goes on.

2. Educate docs, Part 1. The Centers for Medicare & Medicaid Services insists in the 2015 HH PPS final rule that it is educating physicians on their new F2F duties to document home health eligibility and provide that documentation to home health agencies on request. But the reality is that many of your referring physicians won’t know a thing about the new rule, or won’t care.

“Historically, CMS has provided incomplete training to physicians related to home health requirements,” Jump notes. “This adds to the confusion and lack of support from physicians related to home care regulation compliance.”

It’s your job to turn that around and save your claims, experts urge. First you need to tackle awareness of the new duty to turn their records over to you and, if necessary, add documentation to support your claim.

“HHAs need to be meeting with physicians and other referral sources to explain the changes in F2F effective January 1, 2015,” counsels Judy Adams with Adams Home Care Consulting in Asheville, N.C. Explain “the new direction that allows the HHA to provide a summary of the information on eligibility and the ability of the physician to include that summary in their records and make it part of the F2F documentation by signing and dating the summary.”

Uphill battle: Don’t expect it to be easy to accomplish this task. “Getting an audience with the physician and developing agreements for collaboration on the information to support the patient’s eligibility for Medicare home health services” are going to be big challenges, Adams warns.

3. Educate docs, Part 2. In addition to training physicians and their staff on the mechanics of the process, you must work on strengthening their files’ content so they will pass medical review.

“Continue to educate physicians about how to document need for home health services by discipline,” advises clinical consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C. “Stress that a diagnosis alone does not automatically demonstrate need for home health, nor does a diagnosis alone indicate that a patient is homebound.”

Even if a doc incorporates your info to prove eligibility, his record still needs to not contradict your info, CMS stresses in the final rule. “Any information from the HHA … must corroborate the certifying physician’s and/or the acute/post-acute care facility’s own documentation/medical record entries, including the diagnoses and the patient’s condition reported on the comprehensive assessment,” CMS directs in the rule.

4. Follow up on education. CMS hasn’t issued manual instructions pertaining to these requirements yet, Zuber notes. When those updates “do come out, there will doubtless be a need for adjustments,” she advises. “I suspect this transition will take months,” she adds.

5. Create new F2F document. It’s likely that any summary or report you currently compile for your physicians won’t meet the standards of this new requirement (see story, p. 339). You should examine that issue and prepare “an approach to documentation of the findings of the assessment that will be helpful for physicians certifying patients for home health services,” Zuber recommends.

6. Conduct internal audits. Check whether the documentation you have is up to snuff. Use audit findings “as training tools for improvement, pointing out errors but also documentation-meeting requirements” in your ongoing staff education sessions, Jump says.

7. Gear up for increased workload. Est-imate how many additional episodes will require a face-to-face, given the change in the definition to include all episodes for which a start of care (SOC) OASIS is collected, Zuber instructs. (For more information on the definition change, see Eli’s HCW, Vol. XXIII, No. 25).

8. Don’t abandon narratives. While you are working on compliance with the new F2F rules, MACs will continue to put your pre-2015 claims under the microscope under the old narrative standard. The National Association for Home Care & Hospice recommends that HHAs “remain diligent in their efforts to provide sufficient physician narratives for all claims through the end of 2014,” it says. “Be prepared to defend such claims through administrative appeals if they are subject to denials.”

NAHC continues to pursue a lawsuit to resolve the past F2F claim denials and ongoing audits. But for now, “it is crucial that agencies protect themselves directly with individual appeals where necessary,” the trade group urges.

Note: The final rule is at https://federalregister.gov/a/2014-26057.