Can Nursing Home Medical Directors Complete F2F Encounter?
Several members have cited problems obtaining documentation of the required face-to-face encounter for referrals from nursing homes. HCANH asked the National Association for Home Care & Hospice (NAHC) the question: Can nursing home medical directors complete the F2F encounter, similar to hospitalists.
Mary St. Pierre, VP for Regulatory Affairs, provided the following answer: "A CMS Q&A for F2F Encounters implies application of the allowance to all inpatient physicians, including SNF physicians."
Here's the Q&A Mary references:
Do both the plan of care and the certification have to be signed by the same physician?
Prior to Calendar Year 2011, CMS manual guidance required the same physician to sign the certification and the plan of care. Beginning in Calendar Year 2011, CMS will allow additional flexibility associated with the plan of care when a patient is admitted to home health from an acute or post-acute setting. For such patients, many asked that CMS allow the contact between the physician who attended to the patient during an acute or post-acute stay to satisfy the encounter requirement, even when the physician may not follow the patient in the community. These commenters asked CMS to allow such physicians to inform the community certifying physician as the law allows non-physician practitioners (NPPs) to do. We are limited by the law that requires the certifying physician to document that the encounter occurred with himself or herself, or a permitted NPP. To adopt as much flexibility as the law allows, we will allow physicians who attend to the patient in acute and post-acute settings to certify the need for home health care based on their face-to-face contact with the patient (which includes documentation of the face-to-face encounter), initiate the orders (plan of care) for home health services, and "hand off" the patient to his or her community-based physician to review and sign off on the plan of care. As we described above we continue to expect that in most cases the same physician will certify, establish and sign the plan of care. But the flexibility exists for home health post-acute patients if needed.