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 certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient that served as the basis for the certification and eliminates the face-to-face encounter narrative as part of the certification of patient eligibility for the benefit.  Home health agencies should obtain as much documentation from the certifying physician and/or the certifying acute/post-acute care facility as they deem necessary to substantiate that the home health patient eligibility criteria have been met.  Home health agencies are required to provide this documentation to CMS upon request.  

Probe and Educate Reviews

CMS will conduct pre-payment reviews of home health claims for episodes beginning on or after August 1, 2015.  CMS contractors will conduct these reviews using a Probe and Educate strategy through an end date to be determined.  The purpose of this Probe and Educate process is to ensure that HHAs understand the new patient certification requirements.  Because home health episodes have a 60-day certification, CMS anticipates the first documentation requests will be sent on or about October 1, 2015. 

Probe and Educate Process

CMS plans to provide additional details and information on the Probe and Educate process shortly. Please check back to this website for more information.

 

Clinical Template for Home Care Face-to-Face Documentation

The Centers for Medicare & Medicaid Services (CMS) is considering developing a voluntary paper clinical template that could be completed by physicians during their face-to-face examination of a Medicare patient. Once a physician/practitioner has completed the template, the resulting document would become a progress note or clinic note that would be part of the medical record.

In fiscal year (FY) 2014, the Comprehensive Error Rate Testing (CERT) program found that more than half (51.4 percent) of the home health claims were paid improperly. Of the 1308 CERT-reviewed claim lines in error, approximately 90 percent were found to have insufficient documentation errors. The Majority of these errors were due to inadequate documentation supporting the face-to-face requirement.

The first draft of the paper clinical template is available in the download section below.

Comments can be sent to HomeHealthTemplate@cms.hhs.gov.

CMS has received numerous comments on the length of the template and how that makes it difficult for physicians/practitioners to complete the template. CMS reminds commenters about three things:

1. The use of a template is voluntary. Physicians/practitioners will not be required to use it.

2. Once a physician/practitioner completes the template, the resulting document is a progress note or office note that is part of the medical record for that patient. The note must contain all relevant information sufficient for patient care and sufficient for the physician/practitioner to bill for the appropriate level Evaluation and Management service.

3. The template is intended to be a “skip-template” where not all sections are relevant for all patients and therefore can be skipped.

CMS looks forward to receiving specific comments on how to improve the template to increase physicians/practitioners compliance with documenting the necessary clinical elements and possibly decrease the length of the template.

In addition to developing a paper clinical template for documenting a home health face-to-face examination, CMS is developing an electronic clinical template. To see information about the electronic clinical template, see home health (HH) electronic clinical template.

CMS will be hosting a series of Special Open Door Forum calls beginning in February 2015 to provide an opportunity for physicians, home health agencies and/or all other interested parties to provide feedback on both the paper clinical template and the electronic clinical template. The first call was held on February 11, 2015. The second call is scheduled for Wednesday, March 11, 2015 from 1pm – 2pm ET. Dial-in information and slides are in the Downloads section, below.

Paperwork Reduction Act Compliance

In conjunction with the Special Open Door Forum calls we plan to host, we also plan to seek public comment on this voluntary paper clinical template in advance of the submitting a formal information collection request through the Paperwork Reduction Act (PRA) and Office of Management and Budget (OMB) approval process. In accordance with the implementing regulations of the PRA (5 CFR 1320.3(h)(8)), the burden associated with facts or opinions obtained or solicited at or in conjunction with public hearings or meetings is not subject to the PRA. Furthermore, this voluntary Home Health Template is a draft document; the content may subject to additional changes. We are not currently using the form as an information collection instrument. In accordance with the public protections stated in the implementing regulations of the PRA (5 CFR 1320.6), please note that the form is not valid and there is no obligation to use the voluntary form as a collection instrument unless it displays an approved OMB control number.
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 simplified the face-to-face encounter regulatory requirements for home health agencies beginning January 1, 2015.

 

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