According to a report from CGS Medicare, one of the top 5 Medical Review Denial Reasons for home health include the invalidity of physician certification, specifically when the required face-to-face (F2F) encounter was either missing, incomplete, or untimely.
F2F encounter is crucial for coding and certifying Medicare home health services eligibility. Documentation of F2F encounters must be included in the start of care (SOC) certification as a requirement for payment and should clearly identify the primary reason for the home care admission.
Compliance with the documentation requirements for F2F encounters is important to ensure proper coding and avoid claim denials and non-affirmations. There may be instances where home health agencies need to obtain an updated F2F encounter document from physicians to get more comprehensive and precise information about the patient’s condition, but oftentimes, obtaining it is not a walk in the park.
You may refer to our previous article on situations when a new Face-to-Face encounter note might be needed.
Below are some tips on how to obtain complete F2F documentation from physicians:
- Make sure that the From Locator 26 in the CMS 485 includes a statement similar to the example below.
Certification statements may take different forms or formats, provided that they fulfill the content requirements of a valid F2F encounter note. If the agency’s existing physician certification statement does not include the date of the face-to-face encounter, the statement from the example below can be incorporated into another section of the plan of care.
I certify that this patient is confined to his/her home and needs intermittent skilled nursing care, physical therapy, and/or speech therapy or continues to need occupational therapy. The patient is under my care, and I have authorized services on this plan of care and will periodically review the plan. The patient had a face-to-face encounter with an allowed provider type on (date) and the encounter was related to the primary reason for home health care. Physician’s Signature and Date Signed: John Doe, MD 11/05/2016
Physician’s Name and Address:
John Smith, MD
1234 Anchor Drive, Suite 56
Sacarmento, CA 94205
- To help the physician remember where and what to sign on the CMS 485 form, attach a “Sign-Here” sticky note. You can also mark the sticky note to request the date of the most recent F2F encounter.
- To simplify the process of order-signing, utilize your EMR’s Physician Portal, which is available in most EMRs. Ensure that the Portal includes a prompt for the physician to input the date of the F2F encounter.
- Use physician office visits as a chance to market your services. Offer printable progress reports on your patients during the visit and share updates on staff training and care planning. Here are tips to leverage this marketing opportunity:
- A highly effective marketing strategy for physicians is to offer to track care plan oversight (CPO), which makes it easier for them to bill Medicare for CPO.
- To help physicians track the time they spend monitoring the home health care plan, provide them with a Careplan Oversight Documentation Form.
Obtaining new or updated F2F encounter documentation can be a challenging task, mainly because it involves extra coordination with the referring physician who may not always be available or responsive. To address this, ensure that your coders have the expertise to examine the F2F information critically and determine when additional F2F documentation is genuinely necessary.
