Archive for March, 2011

March 31, 2011

CMS says face-to-face does start April 1 (tomorrow!)

The Centers for Medicare & Medicaid Services (CMS) has just issued the following statement on the enforcement of the face to face requirement:

Effective April 1, 2011, the Centers for Medicare & Medicaid Services (CMS) expects home health agencies and hospices have fully established internal processes to comply with the face-to-face encounter requirements mandated by the Affordable Care Act (ACA) for purposes of certification of a patient’s eligibility for Medicare home health services and of recertification for Medicare hospice services.

Section 6407 of the ACA established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner  working with the physician, has seen the patient.  The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care.  Documentation of such an encounter must be present on certifications for patients with starts of care on or after January 1, 2011.

Similarly, section 3131(b) of the ACA requires a hospice physician or nurse practitioner to have a face-to-face encounter with a hospice patient prior to the patient’s 180th-day recertification, and each subsequent recertification.  The encounter must occur no more than 30 calendar days prior to the start of the hospice patient’s third benefit period.  The provision applies to recertification’s on and after January 1, 2011.

On December 23, 2010, due to concerns that some providers needed additional time to establish operational protocols necessary to comply with face-to-face encounter requirements mandated by the Affordable Care Act (ACA) for purposes of certification of a patient’s eligibility for Medicare home health services and of recertification for Medicare hospice services, CMS announced that it will expect full compliance with the requirements, beginning with the second quarter of CY2011.

Throughout the first quarter of 2011, CMS has continued outreach efforts to educate providers, physicians, and other stakeholders affected by these new requirements.  CMS has posted guidance materials including a MLN Matters article, questions and answers documents,  training slides, and  manual instructions which are available via  CMS’ Home Health  Agency Center and Hospice webpages.  CMS’ Office of External Affairs and Regional Offices contacted state and local associations for physicians and home health agencies and advocacy groups to ensure awareness about the face-to-face encounter laws, and to distribute the educational materials.

CMS will continue to address industry questions concerning the new requirements, and will update information on our Web site at


Look at some of my previous blog posts on face-to-face encounters:

NAHC receives many responses to face-to-face

Medicare updates face-to-face questions



March 27, 2011

Coding Clinic tackles HTN and renal sclerosis coding

These Q&As come from the Coding Clinic, Fourth Quarter 2010 Page: 137 Coding advice or code assignments contained in this issue effective with discharges October 1, 2010.

A patient seen in the physician’s office was diagnosed with renal sclerosis due to hypertension. I understand that this should be coded with a code from category 403, Hypertensive chronic kidney disease, but I’m unable to determine what 5th digit should be applied. Please provide some clarification.
Assign code 403.90, Hypertensive chronic kidney disease, unspecified, with chronic kidney disease stage I through stage IV, or unspecified. The fifth digit of “0” should be assigned since there is no chronic kidney disease stage specified. In addition, assign also code 587, Renal sclerosis, unspecified.

A patient with renal sclerosis due to hypertension and stage V chronic kidney disease (CKD) is seen in the doctor’s office. How should this be coded?
Assign code Assign code 403.91, Hypertensive chronic kidney disease, unspecified, with chronic kidney disease stage V or end stage renal disease; code 587, Renal sclerosis, unspecified; and code 585.5, Chronic kidney disease, stage V, for a patient with hypertension due to renal sclerosis and stage V CKD. The fifth digit for subcategory 403.9 is selected on the basis of the documented CKD stage.

© Copyright 1984-2010, American Hospital Association (“AHA”), Chicago, Illinois.  Reproduced with permission. No portion of this publication may be copied without the express, written consent of AHA.

March 23, 2011

HHQI data reports are now available

The January 2011 HHQI reports for ACH and Oral Medications are now available online  These reports provide a look into the potential causative factors of ACH rates and also focus on M2020.
The reports are available in PDF, CSV, XML, MHTML, Excel, TIFF, and Word.
Here is how to get to the data:

1. Go to the HHQI Web site,

2. Click on the Quick Link (right side) for “HHQI Data Access System.” This will lead you to a secure website.
3. Log in with your username and password.
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March 22, 2011

CMS meets with coalition to hear arguments for delaying face-to-face enforcement

This update is provided by NAHC. It is a report on the March 18 meeting with CMS on Face-to-Face Encounter Requirements.

A meeting was held with the Centers for Medicare & Medicaid Services (CMS) last Friday to present and discuss a request to further extend postponement of the home health face-to-face encounter requirements’ enforcement.

Included among the coalition advocating for the delay were:  AARP, the American Medical Association, NAHC, and a wide assortment of physician groups. The American Hospital Association and Catholic Health Association of the United States both have conveyed their support of the extended enforcement delay request.
The purpose of the extension would be to continue and expand physician education efforts regarding the face-to-face encounter requirements and finalize standards for compliance for physician documentation and other issues. One proposal discussed was to allow home health agencies (HHAs) to use the former CMS Form 485 as sufficient documentation.
Jonathan Blum, director of the Center for Medicare, expressed concern at the meeting about an additional extension. Specifically, Blum questioned whether physicians would be more ready in July than they are today and whether the best way to bring about compliance isn’t simply to put the requirements into effect.
Responded to these concerns, the physician groups noted that past experience indicates that a period of six months normally is needed to get the message to “filter through” to physicians in the field, no matter how hard parties try to speed up the process. Beneficiary advocates expressed their concerns that patients may be denied admission to care or may be subject to discharge if the face-to-face encounter and documentation are not completed within 30 days.

Blum reminded attendees of the meeting that the final rule setting forth the face-to-face requirements is based on the health care reform law Congress passed, and that there is little flexibility for CMS in the matter.

Blum promised to respond to the suspension request early this week, given that the enforcement date is currently April 1.
The odds favor CMS granting the further extension of suspension of the rule’s enforcement. The unprecedented coalition of parties presented a persuasive case for the extension on the merits of doing so.

March 16, 2011

G codes focus on the most important reason for admission

Question: What G-code would be used for initial patient admission into a HHA? Patient is discharged from hospital with CHF exacerbation, new meds. SN does complete assessment, reviews all new and continued medications, medication and disease process teaching, etc., and completes the OASIS, 485, etc.
Lisa says: Assign the G code that reflects what was most important about the visit remembering that the OASIS assessment is not, by itself, billable.