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Is relief finally in sight for home health agencies on the face-to-face?

It should be no surprise to the home health industry, who have had reported losses of tens of thousands of dollars from inadequate face-to-face encounter documentation, that the face-to-face has been the recent focus of healthcare news, CMS and Medicare Home Health Part A Contractor communications, initiatives and trainings.

  • In the first quarter of 2014, newsletters from the Medicare Home Health Part A Contractors reported over 80% of claim denials are related to face-to-face encounter requirements not being met and started providing recommendations to providers on how to avoid them.
  • At the March on Washington, the National Association of Homecare (NAHC) announced a planned lawsuit against CMS which would include three arguments relating to the face-to-face:
  1. Argument that the requirement for the physician narrative is outside of CMS authority and that the ACA provides that a physician must only document that the encounter occurred.
  2. Argument that CMS has not established standards for compliance that can be adequately understood and applied by physicians and home health agencies.
  3. Argument that Medicare cannot deny a claim based on an allegation of insufficient documentation unless it reviews the entire medical record.
  • On April 22nd, CMS hosted an Open Door Forum on a “suggested” Home Health Electronic Clinical Template. The purpose of the electronic template is to create a set of structured clinical elements that can be incorporated by vendors into their systems and will assist physicians when documenting the Home Health (HH) face-to-face encounter for Medicare purposes. CMS will be hosting additional Open Door Forum calls in 2014 to give interested parties a chance to provide feedback on the template. Additional information on this initiative can be found here.
  • Medicare Home Health Part A Contractors are scheduling many webinars on the face-to-face encounter requirements and are encouraging providers to attend.
  • Last, a study released by the Department of Health and Human Services Office of the Inspector General in April, 2014 reported 32% of home health claims requiring face-to-face encounters did not meet Medicare requirements, resulting in 2 billion dollars of payments that should not have been made. As a result of this study, the OIG offered the following recommendations which were agreed to by CMS:
  1. Consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation
  2. Develop a specific strategy to communicate directly with physicians about the face-to-face requirement
  3. Develop other oversight mechanisms for the face-to-face requirement

Home health agencies have been citing for years that they are being penalized for physician non-compliance relating to the face-to-face encounter which is a requirement for home health coverage and reimbursement. It appears the home health industry is finally being heard and the recent developments are showing a shift by CMS toward the source, the physician, to correct non-compliance issues relating to the face-to face encounter.

clinician holding her patients hands

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