Face to Face 2013

By  guest blogger-Brandi Whitemyer, BSN,RN, HCS-D,COS-C

Since its implementation in 2011, face-to-face encounter requirements have presented home health agencies with confusing and monumental challenges that impact payment, referral relationships, documentation, and agency workflow. As agencies rise to meet these challenges, it seems questions arise faster than answers in an industry pushed to fulfill yet another demand. Some of the toughest scenarios presented by face-to-face challenges can often only be solved with the assistance of an industry expert. Don’t let your agency be fooled and lose valuable revenue by assuming the answers to your face-to-face questions are easy.

Some of the most common and confounding issues involve late face-to-face encounters. While CMS has provided guidance on these scenarios, resolving them nevertheless involves attention to detail and patience to assure you don’t lose revenue. For example, does your agency know what to do in the following scenario? An encounter you thought occurred on day 28 never happened, only to find out the patient’s encounter occurred 70 days following the agency’s original start of care date. How should your agency act now?

According to CMS Q&As released as of April 2012, you will need to count back 30 days from the late encounter, identify the closest billable visit on or after that date (which will become your new SOC date), and create a new start of care OASIS using those M item response from the OASIS completed closest to that identified first billable visit date. Previous OASIS (including the SOC and any recertification completed) will need to be deleted per CMS guidance prior to the submission of any newly generated OASIS as well. In this process, you will need to assure that as you adjust your episode dates, you generate new plans of care to cover the corrected episode dates, and have these signed by the physician as well. Sounds simple enough right? Maybe, but too often it seems that one simple situation like this can create an avalanche of issues and questions.

For example:

Q: Why delete the OASIS rather than inactivate it?

A: CMS does not require nor want OASIS data on patient episodes that are considered non-covered. In this case, the original OASIS completed are representative of non-covered episodes.

Q: Where do I obtain the M item responses if the closest OASIS is a recertification or a discharge?

A: Use all available M item responses from the available OASIS first, then other M items may be obtained from the ROC or SOC OASIS, whichever was completed closest to the identified first billable visit date.

Q: What about the plan of care? How do I know what interventions and goals to include in which episodes now that the episodes have shifted?

A: As you may have varying interventions and goals from one episode to the next, you will need to review each original episode alongside the revised episode to assess what interventions and goals to include in each newly generated plan of care. Remember that the care you provided at any time must be supported by orders, either within the plan of care or supplemental.

These are just a few of the questions that can come up and, while CMS has issued a myriad of guidance on the issue, navigating a sticky face-to-face issue can still be confusing and time consuming. Unfortunately, the burden of the face-to-face falls on the home health agency, and handling any face-to-face scenario incorrectly can put your claims at risk and risk important revenue for your agency. Be sure to educate your agency staff to assure face-to-face compliance and reduce your risk. Selman-Holman & Associates can help your agency with any number of questions and issues related to face to face, including medical reviews and appeal of claim denials related to face-to-face issues. Don’t take a chance and risk your agency’s bottom line.

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