Earlier this year, Northwest Community Hospital (NCH) Home Care implemented a new CMS regulation requiring physicians to document that a Face-to-Face (F2F) encounter has occurred with a patient to certify home care eligibility. This is in accord with the Final Regulation that was issued by the Centers for Medicare and Medicaid (CMS) in April 2011. NCH medical staff members have been responsive and collaborative with Home Care staff, helping to maintain successful transitions of care during the adoption of this regulation.
“We would like to express our gratitude to the medical staff for their cooperation, flexibility and adoption of the revised Face-to-Face encounter form and protocol,” says Judie Truelsen, RN, BSN, director of NCH Home Care. “Doctors are doing a wonderful job in helping us to achieve compliance with meeting this new regulation.”
While the longstanding requirement that physicians order and certify the need for home care services remains unchanged, the new CMS guidelines assure that the patient has actually seen a physician in the 90 days prior to or 30 days following the start of the home care episode and that the patient qualifies for skilled home care services. If the requirements for F2F encounters are not met, home care agencies will not be reimbursed for their services.
As a result, many home care agencies now require F2F certification be completed and received prior to initiating care, ultimately jeopardizing the start of home care services for some patients. In order to avoid such a delay, when necessary, NCH Home Care will work with physicians and patients to obtain the completed F2F form after the start of home care.
“With this new process in place, our home care staff is working closely with doctors to ensure care is initiated as soon as possible,” Truelsen says. “That sometimes means face to face encounter forms are completed after home care services are underway. It’s an approach that puts the best interest of the patient first while also accommodating physicians’ busy schedules.”
Physicians who have questions about NCH Home Care’s referral process and documentation requirements should contact Judie Truelsen at 847.618.7860, or Roberta Giolli, NCH Home Care office manager, at 847.618.7818.
To date, CMS has little feedback from physicians regarding the F2F regulation and process. To express your opinion, please contact Lori Anderson, director of the Chronic Care Policy Group at the CMS, by calling 410.786.6190 or e-mailing Lori.Anderson@cms.hhs.gov.
For Your Convenience
Any NCH Home Care orders, including the F2F form, can be dropped in the Home Care mailbox located in the Doctors’ Lounge.