Medicare Compliance & Reimbursement

You soon may find out just how easy or hard the new face-to-face physician encounter requirements will be to meet. The Centers for Medicare & Medicaid Services (CMS) plans to unveil the next version of its “Home Health Electronic and Paper Clinical Template” prior to its newly announced April 28 Open Door Forum on the form. CMS had formerly planned to have forums on April 8 and May 6, but it consolidated them into the one “final” call at the end of this month, the agency says in a post on its website. CMS first proposed the template last May, but it floated a very different version of the form in January — a version given a big thumbs down from industry experts.

In February, CMS issued a form with yet more revisions, including shortening the electronic template from five to three pages and including more checkboxes with fewer narrative portions. Now, home health agencies hope CMS will include more of their suggestions in the next iteration due out this month.

For example: “The paper template went from a combination of checkboxes and narratives to a form that requires all narrative responses,” notes the National Association for Home Care & Hospice. “This appears to contradict what participants on the last ODF call clearly expressed — a desire for a paper clinical template that contained more predetermined language with checkboxes.”

HHAs also hope to see CMS clear up confusing and contradictory statements from the last forum on how physicians may incorporate HHA documentation into their own records for F2F support.

See links to the slides and forms from the March call in the “Downloads” sections at www.cms.gov/Research-Statistics-Data-and-Systems/Computer-Data-and-Systems/Electronic-Clinical-Templates/HomeHealthHHElectronicClinicalTemplate.html and www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/Home_Health_Medical_Review_Update.html