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:
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.
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.
