Check box does not meet F2F requirements, but labels might

These questions are the Q&As from NAHC from questions that the organization has received on the face-to-face encounter issue.

Question:  Clarify the regulatory requirement of no standardized language. To be used in documentation of F2F are we able to create a form that contains check box options for the physicians in regards to diagnosis, etc.?
Answer: A check box would not meet CMS’ intent since the agency would be providing prescribed verbiage that a physician must choose from. This “standardized” language may not fit with the clinical condition of the patient. The full text from CMS in the Federal Register reads: “The law requires this as a condition for HH payment. We proposed that the documentation of the encounter be a separate and distinct section of, or an addendum to, the certification, and that the documentation include why the clinical findings of the encounter support HH eligibility. We believe that our proposed documentation requirements meet the Congress’ intent for more physician involvement in determining the patient’s eligibility and managing the care plan. We believe that were we to allow the HHA to craft standard language which the physician would then simply sign, we would not achieve the sort of physician involvement in the eligibility determination and care plan which was the Congress’ intent. As such, we believe that if a HHA were to develop standardized encounter language to be signed by the physician, they would not be adhering to the statutory payment requirements that the “physician document” the encounter.”

Question:  May a home health agency put labels on a form for the physician to complete?
Answer: When asked if it would, however, be acceptable for the agency to at least label the section of the 485 or addendum where the physician’s documentation should be placed, titling it for example “Physician Verification of Face-to-Face Encounter,” and then to include subheadings which include: Date of Encounter, Medical Condition for Encounter, Services Needed, Clinical Findings, Homebound Status, Physician Signature, Date. CMS responded Yes, this is fine.  As long as the info/clinical findings and how the findings support eligibility are documented by the physician, in his/her own words.

Question:   If a hospitalist documents the F2F and certifies the patient, is the primary physician (who will sign the 485 and oversee the episode of care) required to complete a face to face as well?  Or does the hospitalists F2F meet the requirement?
Answer: No, a second face-to-face by the physician ordering services and signing the plan of care is not required.

Question:   If a F2F encounter occurred within the past 90 days prior to referral for homecare and the reason for the F2F was not related to the homecare referral we must then get an additional F2F encounter documented?
Answer: Yes a second encounter will be required.

Question:   I thought the face to face for homecare was effective for admissions as of 1/1/11?
Answer: The face-to-face encounter is required for any patient with a Start of Care Medicare fee-for-service episode 1/1/11 and after. It is not required for recertification episodes.

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