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 physician or a non-physician practitioner to have a face-to-face encounter with the beneficiary before a physician certifies the beneficiary’s eligibility for the home health benefit. One aspect of the certification is for the certifying physician to certify (attest) that the face-to-face encounter occurred and document the date of the encounter. For medical review purposes, Medicare requires documentation in the certifying physician’s medical records and/or the acute/post-acute care facility’s medical records to be used as the basis for certification of patient eligibility. This documentation must include the clinical note or discharge summary for the face-to-face encounter.  To avoid home health claims payment denials or improper payment recoveries agencies and physicians must understand Medicare’s requirements.

“…the industry is essentially on the cusp of all providers needing a modern and effective way to handle denied claims in lockstep with the transition to value-based care and, to a lesser extent, the upcoming Oct. 1, 2106 date after which the Centers for Medicare and Medicaid Services is poised to demand greater specificity in claims submitted using ICD-10 codes.” — from Healthcare Finance News article

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