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A Guide to Securing Compliant F2F Documentation

Face-to-face (F2F) encounter is crucial in certifying eligibility for Medicare home health services. Documentation of F2F encounters must be included in the start of care (SOC) certification as a requirement for payment and should be related to the primary reason for the home care admission. Subsequent episodes cannot occur without a complete initial certification, which can be a reason for claim denials or non-affirmation in Review Choice Demonstration (RCD) states.

Top Reasons for Non-affirmation or Denials Related to F2F

One of the primary reasons stated in claim denials by MACs is “Certification Missing/Incomplete/Invalid” which encompasses the face-to-face encounter. Let us take a look at the top F2F errors related to this:

  1. F2F encounter is unrelated to the primary reason for home health services
  2. Missing F2F encounter note
  3. Untimely F2F encounter and/or no date of the encounter

Basic F2F Encounter Documentation Requirements

It is important to take note of the following documentation requirements for F2F encounters to avoid claim denials and non-affirmation:

  1. Must be performed by an allowed physician or non-physician practitioner (NPP)
  2. Must be signed and dated by the provider who performed the visit
  3. Must occur within 90 days prior or 30 days after the SOC date
  4. Must include a brief narrative supporting the patient’s homebound status and medical necessity for skilled medical services as part of the certification, or as a signed addendum to the certification. This is usually in the form of an office visit note, in-patient progress or consult note, or discharge H&P/summary.

The narrative should demonstrate or support the following:

  • The encounter is related to the primary reason for home health services.
  • A plan of care has been established and is periodically reviewed by a physician or allowed practitioner.
  • The services are or were furnished while the patient is or was under the care of a physician or allowed practitioner.

Further F2F Guidance

Here are further guidance and clarifications on some complex scenarios on F2F compliance:

  • F2F encounter visits may be done via telehealth with an audio and visual format that allows two-way real-time communication between the provider and the patient. A simple phone call does not count.
  • A completed F2F Certification Statement is not a F2F Encounter. The F2F Encounter includes a comprehensive assessment. Coders must always refer to the F2F encounter note to assign the appropriate primary diagnosis.
  • Ensure that the POC is addressed to the provider that will be signing.
  • Review your referral source because it is critical in determining who is qualified to complete the clinical note and who must sign off on it.
    • If you have a community referral, those allowed to complete the F2F encounter are the physician or the allowed non-physician provider (NP, PA, certified nurse-midwife, or certified nurse specialist). It must be signed by the same physician or provider.
    • If you have an acute or post-acute facility referral, the facility physician or their non-physician provider can complete the F2F encounter. The SOC and POC may be signed by the same person with the acknowledgment from the certifying provider that they have properly reviewed the encounter.

Staying on Top of Compliance Standards

As a requirement for payment, getting everything right in documenting F2F encounters is very crucial, yet it can be tricky. Aside from your intake team, your QA and coding partner should help review your F2F compliance.

Furthermore, making sure all Medicare guidelines and CMS standards are accurately covered in your documentation can be overwhelming. One way to alleviate this burden is to outsource your clinical back-office functions—including documentation compliance—to a specialized team. This way, you can focus your efforts on aspects that drive growth, such as improving patient care, in-house clinical staffing, and pursuing more patient referrals.

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