Table of Content
The Service is a paid subscription service, and as such End User agrees that his/her access shall only be restricted to the term and level of subscription term for which DecisionHealth has received payment. In light of these new considerations and mandates, all home health agencies should review their current Compliance Plan to verify that these new risk issues have been incorporated into the plan. If you have not developed and implemented an effective Compliance Plan, we recommend that you immediately contact qualified legal counsel and engage them to prepare an effective Compliance Plan which takes your organization’s specific risks into account. More importantly, the documentation of the encounter must include specific elements in order be considered valid. There are also discrepancies regarding timing when it comes to face-to-face documentation. Dates are supposed to be included in the body of the certification language theoretically, but back in 2015, questions rose on how EMRs would factor into that.
End User shall be solely responsible for all content transferred by End User or any other party in connection with End User's access and/or use of the Service. The Agreement is a legal and binding instrument entered into as of the date of electronic acceptance by End User (the "Effective Date"), by and between DecisionHealth, LLC ("DecisionHealth"), and End User, the individual or entity entering into this Agreement. DecisionHealth reserves the right to amend this Agreement from time to time without notice to End User. This event explores the strategies for deals, investments and transactions in the home health, home care, hospice and palliative care space. Also, the face-to-face should focus on the main condition rather than a side effect, Decker explained. As an example, one provider turned in a face-to-face that was all about a patient’s depression and anxiety, even though the individual just had undergone a surgery.
About CMS
The regulation has been fully implemented and providers are complying with the requirements. Mary was in the hospital with a hospitalist responsible for her care. The hospitalist worked diligently to diagnose and treat her illness or injury. The hospitalist determines Mary will be confined to her home and will need intermittent skilled nursing care and physical therapy.
Now, more than ever before, it is essential that home health providers ensure that their practices fully comply with these face-to-face encounter documentation requirements, as well as other applicable regulatory requirements. To do so, it is recommended that organizations regularly review their documentation, coding and billing practices. When conducting internal reviews, it is recommended that you discuss the approach to be taken with legal counsel prior to initiating such a review. As a final point, should you identify an overpayment, pursuant to another mandate under the ACA, the identified overpayment must be repaid to the government within 60 days.
I. Common Mistakes on Home Health Face-to-Face Documentation:
Centers for Medicare & Medicaid Services published a list of FAQs, which did say that CMS has intended that to be the case. But it was never written into the regulations specifically, Harder said. UVM Health Network – Home Health & Hospice is a nonprofit home health and hospice provider. We are a mission driven, community-based organization whose focus is to deliver high quality care for all those in need, regardless of ability to pay. The UVM Health Network – Home Health & Hospice greatly appreciates your willingness to work together to comply with this requirement and provide the best possible service to our patients. If this requirement is not met, Medicare or Medicaid will not pay for home health services.
This is needed because the face-to-face encounter documentation often is not explicit about the patient’s homebound status. These therapy services must be reasonable and necessary for the treatment of the patient’s illness or injury or to the restoration or mainteancne of function affected by the patient’s illness or injry within the context of his or her unique medical condition. Skilled nursing services must be reasonable and necessary for the treatment of the patient’s illness or injury.
Physicians & Providers
The Patient Protection Affordable Care Act mandates that a physician have a face-to-face encounter (in-person visit) for Medicare and Medicaid home health services. Any purchaser or user of any materials accessible via the Service is an End User for purposes of this Agreement. If, say, the hospitalist performed face-to-face and also signed the certification, then they have to identify who will be the community physician taking care of that patient, she added.
All rights in and to the content that may be accessed through use of the Service is the property of the respective content owners and may be protected by applicable copyright or other intellectual property laws and treaties. All rights not expressly granted are reserved by DecisionHealth and/or the owner of the Service or other materials. As of January 1, 2015, documentation in the certifying physician's medical records and/or the acute /post-acute care facility's medical records will be used as the basis upon which patient eligibility for the Medicare home health benefit will be determined. Therefore, it falls on the shoulders of the home health provider to bolster the physician’s documentation for the homebound status.
Finally, keep in mind that homebound status does not mean that the beneficiary can never leave the house, Decker said. They can leave their house if it’s infrequent, for periods of relatively short duration. Not only leaving the house to receive medical treatments, but also to attend religious services, or even attending adult day care on a daily basis, all could be allowed without compromising someone’s homebound status. Another area of focus was supplemental documentation to the face-to-face to support the need for home health.
Verify Mary's medical record both in the inpatient facility and the physician's office contain the necessary information. You can use the clinical templates or suggested clinical data elements to assist with documenting the Plan of Care/Certification and face-to-face encounter to support the need for home health services. The face-to-face also has to be for the main reason a patient is coming to home health, Decker noted. For instance, if a patient sees a physician numerous times in the 90 days before the start of care for COPD, but then falls and breaks an ankle and that precipitates the home health episode, that is what the face-to-face has to cover. What further muddies the water is that home health providers are now obviously working with a variety of payers. Some even have more business these days with Medicare Advantage plans than they do with traditional, fee-for-service Medicare.
The HHA is no longer able to care for Mary since there will be no Medicare payment. The license granted herein is expressly conditioned upon your acceptance of all terms and conditions contained in this agreement. If the foregoing terms and conditions are acceptable to you, please indicate your agreement by clicking below on the button labeled "I ACCEPT".
Please click on the links below to download a PDF version of the document. The FTF encounter must occur within 90 days prior to the Start of Care or 30 days after the SOC. The FTF documentation must show the FTF encounter occurred within this timeframe.
This supporting documentation can be created or generated by the agency or be information that the agency has obtained, such as a discharge summary. Certification for home health is already required by physicians. The face-to-face encounter for home health care can be included in the certification documentation or on a separate form.
Providers are also supposed to match the primary diagnosis of the face-to-face encounter with the subsequent plan of care. Face-to-face documentation is already one of the top reasons for those claim denials in Medicare and Medicaid, and also, the regulatory guidelines have recently changed – a further reason why providers need to hone in on best practices. Face-to-face encounter documentation remains a pain point for home health providers. To assist the HHA in providing and receiving appropriate reimbursement for Mary , please submit the appropriate documentation when requested to do so. This will ensure the HHA can receive appropriate Medicare payment and your patient's care will not need interrupted or discontinued. The following documents provide support for completing the documentation of the face-to-face encounter.
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