Medicare Compliance & Reimbursement

Sky high denials due to inadequate F2F documentation sound a wake-up call.

While many experts and home health agencies (HHAs) have given a thumbs down to the new F2F Form that the Centers for Medicare & Medicaid Services (CMS) is offering, don’t be too quick to discount its usefulness. So far CMS is resisting the industry’s pleas to hold off on enforcement of the new face-to-face physician encounter requirements. With sky-high F2F denial rates racking up for reviewed claims, that puts your reimbursement at serious risk.

Concession: CMS has indicated to the National Association for Home Care & Hospice (NAHC) that it “intends to have its contractors re-prioritize their audit resources,” NAHC reports. “The audits will shift away from pre-2015 F2F issues, e.g. the notorious narrative, and refocus on compliance with the new standards.”

However, “this does not mean that CMS will stop auditing pre-2015 claims altogether,” NAHC cautions. “Instead, any such audits will be focused on non-F2F issues or limited, targeted F2F audits.”

Decide Whether To Use New Form Or Other Procedures

The new form CMS has offered for physician F2F compliance has a myriad of flaws (see related story, p. 30). But it still may be the best bet for agencies who are looking to maximize their compliance with the confusing requirement.

“Given the voluntary nature of the form, HHAs and physicians will still be able to achieve documentation compliance by other means such as using existing documents such as the hospital discharge summary and the HHA OASIS assessment provided the certifying physician has signed off on them and includes them in the patient’s record,” NAHC allows. “Still, those compliance standards remain foggy for the home health community.”

HHAs like the idea of having a reliable form that physicians could fill out to meet the confusing F2F requirement. “The payment error rate, now over 50 percent for home health providers, is devastating,” notes Pat Jump with Rice Lake, Wis.-based Acorn’s End Training & Consulting. “So something needs to be done.”

Cheer up: The new form isn’t all bad. “The one thing the template does is take some of the guess work out of what CMS really wants to see for documentation,” Jump allows. “It helps that some of the language is present on the form and that providers can complete a portion of the form.”

HHAs can fill out information on the top of the form identifying the patient, the provider, and location of the F2F encounter (Section A). And it’s not the physician himself who has to fill out the clinical portion (Section B). “This section is used to gather clinical information to determine whether the patient is home bound and what skilled services the patient requires,” CMS explains in the form’s footnotes. Section B “cannot be completed by the home health agency. While this section may be completed by a non-provider clinician, or a provider employee, it must be reviewed and signed (in Section C) by the ordering provider,” CMS instructs.

The part the physician or her staff must fill out at least “uses a combination of check boxes and directed questions that should speed things up for the physician,” NAHC says.

Plus: The template isn’t quite as voluminous as the one originally proposed last year. “It is a slimmed-down revision of the earlier EHR version and covers only the F2F elements rather than a full scale clinical assessment of the patient,” NAHC notes.

Form Not Set In Stone

While HHAs and physicians don’t want to see yet more change to F2F documentation, you do have a chance to furnish input that could improve the template. CMS will hold Special Open Door Forums on the form. And you can furnish feedback via email at Home HealthTemplate@cms.hhs.gov, CMS says.

Meanwhile: NAHC continues to press for a phase-in of the new requirements, and to proceed with its lawsuit opposing the physician narrative, the trade group says. “In the interim, HHAs should fully consider administrative appeals of any pre-2015 F2F-related claim denials,” NAHC urges.

Note: CMS will issue dial-in information for the Special Open Door forum at www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/Electronic-Clinical-Templates/HomeHealthHHElectronicClinicalTemplate.html.