Wey-Wey Kwok - medicareadvocacy.org€¦ · is a new soc & f2f encounter required?

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Copyright © Center for Medicare Advocacy

FACE TO FACE ENCOUNTERS &

HOME HEALTH CERTIFICATION

Wey-Wey KwokSenior Attorney

[email protected]

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mailto:[email protected]


Copyright © Center for Medicare Advocacy 2

The Center for Medicare Advocacy is a national non-profit law

organization founded in 1986 that works to advance access to comprehensive Medicare and quality health care

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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.



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.



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



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.




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.




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




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



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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Wey-Wey Kwok - medicareadvocacy.org€¦ · is a new soc & f2f encounter required?

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