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Discussion

Face-to-Face Rule

With less than three weeks left in the year, how is your agency making plans to implement the face-to-face rule? How do you expect this to impact your agency?

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    what's the face to face rule?

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    With less than three weeks left in the year, how is your agency making plans to implement the face-to-face rule? How do you expect this to impact your agency?

    KateRN1 i did some reading on this subject,,,another interesting challenge!!!!

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    yay! we have more do and track and write policies for!!!!!!!!!!

    we are planning to ask at receipt of referral and having the opening clinician ask when the md was last seen or when is the next appointment. we will have the intake person make a follow-up phone call to make sure the encounter was made. i'm sure we will tweak this many times before we are pleased. we are sending out faxes/mailings to all of our doctors with the info below about the face-to-face (ftf) from [color=#0e774a]cahabagba.com

    the final rule amended the code of federal regulations, 42cfr part 424.22 as follows:

    1. the physician responsible for performing the start of care home health certification must document that a face-to-face (ftf) encounter was performed within 90 days prior to the start of care (soc) or 30 days after the soc.
    2. the encounter must be related to the primary reason for admission to homecare. if the ftf encounter occurred within 90 days of the soc but is not related to the primary reason for home health, the npp or certifying physician must have a ftf encounter within 30 days after the soc.

    * the ftf encounter may be performed by either the certifying physician or a qualified non-physician practitioner (npp). an npp is defined as a nurse practitioner, clinical nurse specialist as defined in the social security act section 1861(aa)(5) who is working in collaboration with the physician as defined by state law, a certified nurse midwife as defined in section 1861(gg) of the act, or a physician assistant (as defined in the social security act section 1861(aa)(5)) under the supervision of a physician.

    * the ftf encounter may not be performed by either a physician or an npp whom is employed by or has a financial relationship with the home health agency as defined in section 411.354. additional information regarding this topic is also accessible in section 424.24.

    * the npp performing the ftf encounter must document the clinical findings of the ftf encounter and communicate those findings to the certifying physician. the certifying physician is responsible for documenting the ftf encounter took place.

    * the ftf encounter may be performed through telehealth. this must be performed via medicare eligible telehealth services. for information on what constitutes medicare eligible telehealth services, see overview telehealth

    * documentation of the ftf encounter must be a separate and distinct section of, or an addendum to, the certification and must be clearly titled, dated, and signed by the certifying physician. the documentation must include the date of the encounter, that the condition for which the patient was being treated in the encounter is related to the primary reason the patient requires home care services, and why the clinical findings of the encounter support that the patient is homebound and in need of medicare covered home health services. the home health agency may not formulate standard language on the certification forms related to the encounter.

    these regulations take effect for home health start of care certifications occurring on or after january 1, 2011. as a reminder, all certification documentation, including the ftf encounter documentation, must be signed and dated by the physician before the claim is submitted to medicare.

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    I see this as a HUGE challenge facing home health care. It is going to require a lot more work on the part of the physician to document the face to face encounter. Unfortunately, I see that as being a deterrent for the physician in referring to home health. Who really wants to do more documentation?

    My agency has prepared for this by creating the form that will be faxed along with the certification. The physician or physician-designee has to complete the form and the physician signs it. That's as far as we've gotten. I'm sure something also needs to be done in the intake department to verify if an encounter has already occured within the 90 day period.

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    • Experts

    One more requirement to fall by the wayside or receive less than full attention.

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    • Experts

    this one won't fall by the wayside: if encounter not performed for medicare clients, home care agency does not get paid.

    our emr vendor mckession has software section to list and track encounters so report can be run. additionally, my intake staff will list on our referral log "f2f" for those patients not seen by attending doctor prior to soc or have scheduled appointment within first 30 days afterwards to asssist intracking. less than 5% of our agency referrals are from pcp office directly.

    with a large portion of hospitalist referrals, many having no pcp, i do forsee us making more referrals at point of intake to visiting physician/np practices from my intake office.

    biggest impact: getting doctors to handwrite info to meet regs "no standardized language" per cms on encounter section aloning with dating doccument.

    patients will be notified that agency will discharge on day 31 if patient hasn't seen docotr signing homecare orders within law timeframes. agency can not pass onto patient cost of care per cms.

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    Good News!! CMS has decided to postpone the enforcement of this new reg until the 2nd quarter of 2011. They recommend agencies go ahead and begin complying with the f2f requirement now to trouble-shoot, but will not enforce at this time. WooHoo!!!

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    F2F is basically starting 1/1/11, but agencies will get a pass on any citation for 3 months. I developed a simple form for our referral sources, but we might actually go with an adendum to the 485. I can understand why it needs done. Nothing like getting a referral on someone who has not seen a Dr. in years.

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    We've already implemented it and so far seems to be doing ok. Some tweaks needed of course. Marketer has one form they must get and if they individual hasnt been seen then we make the appt for them in the home on the SOC with our form. Also ensuring that the physician is going to sign our orders. Both are turned in at SOC and also have been placed on our oasis and 485 software in the office. I'm having more issues getting the doctors to have signed Lab requistions/orders for the labs new requirement with they must have the doctors actual signature on them. This one has finally been postponed for a little while.

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