Archive | Face2Face

Probe and Educate Alive and Well for 2017

Since 2015 CMS has instructed Medicare Administrative Contractors (MACs) to request records for 5 claims from each home health agency within their jurisdiction to review on a pre-payment basis.  For the time being, this practice (affectionately known as Probe and Educate) isn’t’ going anywhere. 2017 brings us to round 2 of the Probe and Educate […]

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New material from CMS offers clarity on Face to Face

In the early days of CMS’ new nationwide home health “Probe and Educate” review, nearly 90% of claims have been denied – with MAC NGS denying 97% of all claims reviewed! It’s clear that issues remain with face-to-face (F2F) documentation despite recent regulatory changes. For a few years the Affordable Care Act has required a […]

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Tips for Getting Through the Second Round of Probe and Educate

The National Association of Home Care and Hospice had a helpful F2F article in one of last week’s NAHC Reports that I believe is worth sharing. The article reports on trends related to the first round of CMS Probe & Educate audits.  It offers guidance on the use of F2F forms and clarifies the documentation […]

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Industry Greets New Face-to-Face Rule with Cautious Optimism

From Home Helth Care News By Kourtney Liepelt | February 1, 2016 It seems the Centers for Medicare & Medicaid Services (CMS) learned from a rocky rollout for its Medicare face-to-face rule, as it released similar regulations with several key distinctions last week for home care services covered by Medicaid. “We’re very appreciative of the […]

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Federal Court Rules In Favor of Medicare While Restricting Scope of F2F Narrative

U.S District Judge Christopher R. Cooper issued his decision yesterday in the lawsuit brought by the National Association for Home Care & Hospice (NAHC) challenging the validity of the Medicare rule that a physician provide a narrative to document the face-to-face encounter with the patient. Judge Cooper ruled against NAHC and granted “Summary Judgment” to […]

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Update on Face to Face

On November 6, 2014, The Centers for Medicare & Medicaid Services (CMS) issued final rule CMS-1611-F, Calendar Year (CY) 2015 Home Health Prospective Payment System (HH PPS) Final Rule.  The HH PPS final rule (79 FR 66032) finalized a change that, beginning, January 1, 2015, requires home health agencies (HHA) to obtain documentation from the […]

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F2F Lawsuit Goes to Court

The National Association of Home Care & Hospice’s (NAHC) lawsuit regarding the Medicare face-to-face regulation had its day in court on August 6th.  The NAHC lawsuit challenged the validity of the physician narrative as documentation that the F2F requirement had been met.  NAHC’s VP of Law William Dombi argued that Congress intended the F2F requirement as a […]

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CMS Chimes in on Face to Face

CMS released two policy issuances that are worthy of note. An update of the policy provisions on face-to-face certifications: This is not a new policy, but a codification of the 2015 regulatory amendments into the CMS manual. One somewhat interesting element is that CMS indicates that as a matter of medical review, the physician’s record […]

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CMS Announces Series of Calls on F2F Documentation

The Centers for Medicare and Medicaid Service (CMS) announced the first in a series of special Open Door Forums on Wednesday, Feb. 11 at 1:00 p.m. ET to discuss the voluntary draft paper and electronic clinical templates to reduce the burden of the face to face narrative mandate. Special Open Door Participation Instructions: Participant Dial-In […]

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Congress Issues Report to CMS Asking it to Justify its Face-to-Face Policy

As part of its analysis of the ongoing face-to-face issue, Inside Health Policy recently summed up the continuing frustration the home care and hospice community feel surrounding the face-to-face requirement: “[The Home Care] Industry has viewed the Affordable Care Act’s face-to-face requirements as flawed and unclear. As part of the face-to-face documentation, a physician narrative […]

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Congressional Budget Calls for CMS Report on F2F, Rebasing

The $1.1 trillion spending plan approved by the Congress includes ‘report language’ on the Medicare Home Health face-to-face (F2F) rule and Medicare home health rebasing. While ‘report language’ is non-binding, it nevertheless could have policy implications if implemented by the Centers for Medicare and Medicaid Services (CMS). Below is the language contained in the bill: […]

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OIG Says Face-to-face Isn’t Working

A recent study by the Office of Inspector General found that the face-to-face rule for home health fails nearly one third of the time. According to the report, 32 percent of home health claims requiring face-to-face encounters failed to meet Medicare rules, resulting in $2 billion in payments that should not have been made. Furthermore, […]

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