wey-wey kwok - medicareadvocacy.org€¦ · is a new soc & f2f encounter required?
TRANSCRIPT
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FACE TO FACE ENCOUNTERS &
HOME HEALTH CERTIFICATION
Wey-Wey KwokSenior Attorney
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FACE TO FACE ENCOUNTER
• Required for Start of Care home
health certifications
• No earlier than 90 days prior to or
later than 30 days after SOC
• Must be related to primary reason for
home health admission
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WHO CAN PERFORM F2F?
A. Certifying MD
B. MD who cared for patient in acute or
post-acute facility (w/ privileges)
Note: If facility MD certifies, must
identify the physician who will follow
the patient in the community.
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WHO CAN PERFORM F2F?
(CONT’D)
C. Qualified non-physician
practitioner (NPP) working in
collaboration w/ or under
supervision of the above:
NP, PA, CNS, CNMW
Note: May not certify
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PART 1: CERTIFICATION
REQUIREMENT
• No mandated format. Ex., Form 485
• Must certify by signing and dating, that
patient is homebound, needs skilled care, is
under care of a physician who established
& reviews the plan of care and there was a
Timely F2F encounter (specify DATE),
related to primary reason for home care,
performed by allowed entity.
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PART 2: SUPPORTING
DOCUMENTATION
REQUIREMENT
As of 1/1/15, the certifying MD’s and/or the
acute/post-acute care facility’s medical
records (if patient directly admitted to home
health) are used as basis for determining
patient’s eligibility for home health benefit.
HHA must provide supporting documentation
to review entities and/or CMS, on request.
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SUPPORTING DOCUMENTATION
REQUIREMENT, CONT’D.
Certifying MD and/or facility’s medical
records must justify patient’s referral for home
care, including:
- Homebound status
- Need for skilled services
- Actual F2F clinical note showing it was
timely, related to reason for home care,
performed by allowed provider type.
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SOME EXAMPLES OF SUPPORTING
DOCUMENTATION
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Physician’s Clinical/Progress Note
CMS Voluntary Paper or Electronic Template
Inpatient Progress Note
Inpatient Discharge Summary. If used as F2F visit:
- must reflect clinical findings
- show it was communicated to certifying MD
- signed/dated by certifying MD
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Information from HHA can be incorporated into
certifying MD’s medical record to support HB status
and need for skilled care. Info must be corroborated
by other medical entries in the MD’s or facility’s
records for the patient. Let MD know to:
1. Accept info by signing & dating,
2. File it in physician's record, &
3. Return signed/dated copy to the HHA
What if physician/facility medical
record is insufficient?
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PHYSICIAN/FACILITY
COMPLIANCE
At HHAs’ request, certifying MDs & facilities
must provide supporting documentation.
CMS will deny MD’s claims for oversight if HHA
claim is denied for incomplete cert/recert or
insufficient supporting documentation.
Non-compliance may subject MDs & facilities to
increased reviews.
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F2F IS NOT A BASIS FOR PATIENT
LIABILITY
CMS has indicated that ABN must not
be used to transfer liability to a
beneficiary when the F2F requirement is
not met.
F2F is a technical requirement for
payment, not a coverage requirement.
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DISCHARGES FOR LACK OF F2F
ENCOUNTER
If HHA chooses to terminate services for failure to
meet F2F encounter requirement, HHA should give
notice (HHCCN) in advance so that patient can
attempt to cure.
NOTE: As a condition of participation, HHAs must
coordinate all aspects of a patient’s care needs,
including working w/ MD to obtain completed
certification & updated, signed care plan.
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IS A NEW SOC & F2F ENCOUNTER
REQUIRED?
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Example: Patient is discharged with goals met,
but is then readmitted to HHA within the same
60-day episode period and for the same condition
that triggered the original admission.
YES, if discharged and later readmitted, any new
Start of Care OASIS will require a F2F.
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IS A NEW SOC & F2F ENCOUNTER
REQUIRED? CONT’D.
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Example: Patient is hospitalized & returns to
HH during last 5 days of current episode.
No, CMS clarified that only a Resumption of
Care (ROC) is necessary in this instance.
The next episode of care would be considered
continuous & require recertification.
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IS A NEW SOC & F2F ENCOUNTER
REQUIRED? CONT’D.
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Example: Patient is recertified during days 56-60, but
is then hospitalized, and returns home on day 61 (1st
day of next episode).
It depends. If HHRG stays the same, the next episode
considered continuous (recert). If HHRG changes,
then a new certification, SOC OASIS & F2F is
required.
MBPM Ch. 7, § 10.10; CMS-1611-F
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IS A NEW SOC & F2F ENCOUNTER
REQUIRED? CONT’D.
Example: Patient is recertified during days 56-60,
but is then hospitalized & remains in hospital past
day 61.
YES, for patients discharged and later readmitted,
any new OASIS start of care will require a F2F.
MBPM Ch. 7, § 10.10
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RECERTIFICATION:
SUBSEQUENT EPISODES OF
CARE
Medicare does not limit the number of
continuous episode recertifications for patients
who continue to be eligible for the home health
benefit.
MBPM Ch. 7, § 30.5.2
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PHYSICIAN ESTIMATE
OF LENGTH OF SERVICES
Every recertification for the Medicare home
health benefit must include the physician’s
estimate of how much longer skilled services
will be needed.
42 CFR § 424.22(b)(2); CR-9119; MBPM Ch. 7 § 30.5.2
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PHYSICIAN’S ESTIMATE OF
LENGTH OF SERVICES
REQUIREMENT
No manner specified for estimate to be presented.
Verbal order that includes an estimate is acceptable.
HHA cannot estimate the length of services.
HHA can provide a written statement with a blank
space left for physician to fill in.
Visit frequency & duration on POC will not suffice.
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CERTIFYING/RECERTIFYING
PATIENT FOR MANAGEMENT &
EVALUATION OF CARE PLAN
Where patient’s sole skilled service need is for
skilled oversight of unskilled services, the physician
must include a brief narrative
describing the clinical justification of this
need in the certification (or an addendum).
MBPM Ch. 7 §§ 30.5.1 and 40.1.2.2;
See also 42 CFR §424.22(a)(1)(i)
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