July/August 2013

Face-to-Face Documentation Requirements

The Centers for Medicare & Medicaid Services (CMS) has recently announced that the department will be requiring more extensive and specific information and performing more comprehensive reviews of the required face-to-face (F2F) documentation that physicians must complete in order to certify patients for home care. Their focus is on the narrative linking the diagnoses and findings from the F2F encounter to the patient's homebound status and skilled need.

Acceptable F2F documentation does not need to be lengthy, but must show the date of the F2F encounter. Additionally, according to CMS, "face-to-face documentation must contain a brief narrative which describes how the patient's clinical condition as seen during that (face-to-face) encounter supports the patient's homebound status and need for skilled services."

Documentation must include details showing how specific clinical findings support homebound status and skilled needs. An increase in denials to home care agencies for entire episodes of care has been reported due to insufficient documentation by physicians. CMS will no longer accept a diagnosis or procedure as reason alone and must include resulting clinical limitations or findings. It should be noted that the F2F form can be completed by ANY physician's representative; however, it must be signed and dated by the certifying physician.

Home Care agencies cannot bill CMS for any skilled services unless the F2F form is completed and in the hands of the agency prior to billing. Patients could potentially be denied home care services if the F2F form meeting CMS' revised and more detailed requirements is not provided to the home care agency by the certifying physician.

Medicare's increased, focused attention on face-to-face requirements is impacting all of us, as our NCH Home Care has already had thousands of dollars recouped by Medicare and additional requests for documentation from CMS continue to be received by our agency.

For more information, contact Roberta Giolli, Office Manager, NCH Home Care, or Judie Truelsen, Director, NCH Home Care, at 847.618.7800.