Medicare Compliance & Reimbursement

New form may reduce error rate.

Home health agencies are still struggling with face-to-face encounter requirements. It’s the physician who must supply the F2F documentation, but if the Centers for Medicare & Medicaid Services (CMS) finds the record lacking, the HHA pays the price.

HHAs are distressed about the vague face-to-face physician encounter documentation requirements that took effect Jan. 1. That’s when CMS nixed the F2F physician narrative for most patients and instead said a patient’s home care eligibility would be determined based on the physician’s clinical record.

In a December Open Door Forum, CMS spelled out five elements that must be present in the physician’s record for the HHA claim to pass medical review. Two of those can be furnished by the HHA and merely signed into the record by the physician, but three must be in the physician’s record itself, CMS indicated.

CMS has been getting an earful from HHAs protesting the confusing new requirements, both in comments on the 2015 proposed rule and informally from provider and trade groups. Now the agency offers a solution: a “Suggested Voluntary Electronic Clinical Template Elements of a Progress Note Documenting a Face-to-Face Examination for Home Health Services.” CMS offers a paper version of the proposed template as well.

CMS actually proposed this template last May. But it has reintroduced a revised version of the form now.

Why? “In fiscal year (FY) 2014, the Comprehensive Error Rate Testing (CERT) program found that more than half of the home health claims were paid improperly. The 51.4 percent error rate in home health is a substantial increase from the 17.3 error rate in FY 2013,” CMS notes on the F2F template website.

“One of the drivers of the home health error rate is inadequate documentation supporting the face-to-face requirement,” CMS continues. “Of the 630 CERT-reviewed claims found to be errors, 564 (89.5 percent) did not have documentation meeting the face-to-face requirement.”

Tool: “CMS is developing a list of clinical elements within a suggested electronic clinical template that would allow electronic health record vendors to create prompts to assist physicians when documenting the home health (HH) face-to-face encounter for Medicare purposes,” CMS says. “Once completed by the physician, the resulting progress note or clinic note would be part of the medical record.”

HHAs Bemoan Form’s Flaws

While HHAs have been looking for a helping hand with F2F compliance, this wasn’t what most had in mind. “Good grief,” noted clinical expert Lynda Laff with Laff Associates in Hilton Head Island, S.C. “It’s five pages long.”

HHAs that have been struggling to get their physicians to comply with Medicare F2F requirements will not relish the idea of handing over a five-page form for them to fill out.

The template “is quite lengthy,” laments Pat Jump with Rice Lake, Wis.-based Acorn’s End Training & Consulting.

“The prospect of a physician completing a 5-page form is daunting,” admits the National Association for Home Care & Hospice in its analysis of the new form.

Expecting ordering physicians or their staff to fill out this long form is simply “unrealistic,” comments Chicago-based regulatory consultant Rebecca Friedman Zuber.

Another problem: “A significant portion of [the form] must be completed by someone other than the home health provider” Jump notes, (see details, related story, p. 31). The form takes “the control out of the hands of the provider.” That once again leaves agencies on the hook financially for documentation from a provider whose reimbursement is unaffected.

If CMS had instituted this form from the start of F2F, HHAs might have had a fighting chance in getting physicians to use it with minimal complaints. But with so much water under the bridge, docs aren’t receptive to taking on a new form that may be replaced with something else shortly.

“HHAs are weary of all these changes, as are their docs,” Zuber observes.

Bottom line: Due to these flaws, the new form is at best “marginally helpful,” Zuber believes.

“There are so many issues with F2F that I don’t see this template as a satisfactory resolution,” Jump concludes.

Note: See links to the electronic template at www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/Electronic-Clinical-Templates/HomeHealthHHElectronicClinicalTemplate.html and paper template at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/Home_Health_Medical_Review_Update.html.