Home Health & Hospice Week

Medicare is getting serious about face-to-face requirements.

Payment for your subsequent episodes is now at risk if reviewers find your patient’s initial episode face-to-face documentation lacking.

HHH Medicare Administrator Contractor NHIC recently told home health agencies they didn’t have to submit F2F documentation for second or later episodes (see Eli’s HCW, Vol. XXII, No. 20). But MAC CGS is singing a different tune.

"As a result of numerous errors identified by both CGS and the Comprehensive Error Rate Testing (CERT) contractor related to home health face-to-face (FTF) encounter documentation, CGS will be initiating a widespread edit for all home health providers," the MAC says in a message to providers. Claims selected for the edit "will be reviewed for valid FTF encounter documentation, medical necessity compliance with all CMS coverage guidelines, correct billing and coding," CGS specifies.

New requirement: "Beginning July 8, 2013, CGS will begin requesting the initial certification face-to-face (FTF) encounter documentation is submitted with all home health claims selected for Medical Review," the MAC says. "The Centers for Medicare & Medicaid Services (CMS) clarified the ‘face-to-face encounter requirement is necessary for the initial certification, which is a condition of payment. Without a complete initial certification, there cannot be subsequent episodes.’"