Home Health & Hospice Week

Educate, educate, educate.

The face-to-face encounter rule isn't going away, and that means home care providers need to get a grip on this slippery requirement -- the sooner the better. Use these expert tips to help you come into compliance by the April 1 enforcement date:

• Educate physicians. You can't spend enough time educating docs, both before and after the enforcement date, experts agree.

"Spread the word," urges consultant Maur-een M. Corcoran of Vorys Health Care Advisors in Columbus, Ohio. "Inform, educate and remind ... all providers that you come in contact with about the change in regulations."

Don't stop with just the requirements, Corcoran says. Be sure to tell physicians about the consequences of non-compliance -- "the delays or denial that may occur if there isn't correct assessment information."

One-on-one meetings seem to be the most effective for educating physicians and their staff, observes Chicago, Ill.-based consultant Rebecca Friedman Zuber.

You'll find physicians a more receptive audience if you stress that "this change was not made on behalf of the home care providers," advises consultant Pam Warmack with Clinic Connec-tions in Ruston, La. "We are a bigger victim here than the physician is."

Reminder: "Make every possible effort to educate the staff in the MDs' offices," too, counsels consultant Lynda Laff with Laff Associates in Hil-ton Head Island, S.C.

Thanks to recent clarifications from CMS, often it will be the staff who put together the underlying information from the medical record for the physician to sign off on, Zuber expects.

• Widen your education target. Don't just include physicians and their staff in your education efforts. Hospital discharge planners have been crucial to some agencies getting physicians to return F2F paperwork, says consultant Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C. Discharge planners can develop F2F paperwork for the physician to sign based on the docs' notes in the hospital records.

Educating beneficiaries' families is also important, says Corcoran. They'll be the ones who make sure your patients make it to their F2F visits with their physicians.

• Include yourself in education. Last but not least, include agency personnel on the list for education efforts. Agency management should start with a big-picture understanding of the requirement, Laff recommends. They need to understand why law- and policy-makers have imposed these new F2F rules.

"The real reason the regulation exists is that we as an industry have continued to recertify patients who may not actually qualify for the Medicare home health benefit," Laff believes. "Many of these patients have been on service for multiple certifications -- even years under 'observation and assessment' -- without any documented change in condition and without ever visiting the MD. Some have been recertified basically to 'make the MD happy' as a means to stay in the good graces of the MD."

And sometimes the overutilization abuse has turned into outright fraud. "In some parts of the country, unfortunately, the MDs have participated in payment for referrals where the patients do not even qualify for services," Laff notes. "The result is that when this happens, every agency suffers" under increased regulatory requirements like F2F.

Don't miss: Be sure your marketers have a thorough and detailed knowledge of the new F2F requirements. "Marketing staff ... most often encounter the physicians' questions and concerns," Warmack observes.

• Provide examples and forms. You'll have a better chance of getting back your requested F2F documentation if you give physicians sample forms to use. And the likelihood of docs actually completing the documentation correctly will in-crease if you give docs filled-out examples of those forms.

"We have provided physicians with examples of how homebound status is described in home care," Warmack relates. "The examples are not to be used in completing the form, they are for educational purposes only," she cautions.

One of the F2F regulation's major flaws is a lack of a standard form for physicians to use, says a letter to CMS from Reps. Ben Chandler (D-Ky.) and Tim Holden (D-Pa.) (see related story, p. 82).

Two good places for sample forms and educational materials are the National Association for Home Care & Hospice (10 model letters and tools) at http://www.nahc.org/regulatory/home.html -- scroll down to the F2F sections; and the Home Care Asso-ciation for New Jersey (F2F tools including a documentation guide for physicians) at http://www.homecarenj.org/public/HealthCareEncounterTools.html.

You can also furnish physician offices with the Federal Register final rule language and CMSs' F2F Q&As, Warmack offers.

• Troubleshoot F2F documentation. If medical reviewers find your F2F documentation lacking, you can kiss your reimbursement for that patient good-bye.

Use the rest of the dry run period and the beginning of the enforcement period to go over physicians' documentation carefully for adequacy. "My clients have used this preliminary time to identify problem areas with the documentation per physician," Warmack says.

"Most agencies are having to review the forms carefully and send them back to MDs asking for more information," Adams says.

Once you ID the problems, hold meetings with the physicians and/or their staff to point out the problems and discuss ways to prevent them in the future. "Thus far, the MD staff has been cordial and receptive," Warmack reports.

• Don't give up. Under the pressure cooker of the April 1 enforcement deadline, it's hard for providers to allow F2F documentation to evolve. F2F, "like every other significant change in process, will just take time, patience, persistence, and most of all effort on the part of agencies," Laff says.

"Like every other change, it will take more than a month or two but [physicians eventually] will sign them appropriately," Laff predicts.