New Requirements for Home Health Certifications AAPC Knowledge Center

Table of Content

• CFR § 424.22 - Requirements for home health...
• Medicare Home Health Face-to-Face Requirement Medicare’s Hospice Benefit: Eligibility, Election, & Duration of Benefits
• Home Health Special Open Door Forum (SODF) Documents
• Medicare Home Health Face-to-Face Requirement...
• USA Government Sites
• Other Benefit Templates

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The face-to-face requirement ensures that the orders and certification for home health... Select the document template you require from our library of legal form samples. Journals.sagepub.com needs to review the security of your connection before proceeding. As a contributor you will produce quality content for the business of healthcare, taking the Knowledge Center forward with your knowhow and expertise.

CFR § 424.22 - Requirements for home health...

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Documentation of the face-to-face encounter must include a statement demonstrating that the encounter was performed for the same condition or conditions that represent the primary reason for home care services. In addition, the documentation must include an explanation of the reasons for the patient’s homebound status and the medical necessity of either intermittent skilled therapy and/or skilled nursing services. Also, it is important to note that for patients referred directly from a hospital, a hospitalist could conduct the face-to-face encounter. To qualify, the hospitalist would need to document the encounter, perform the certification and review of the initial plan of care, and then clearly communicate the name of the physician in the community (i.e., the patient’s primary care physician) who will continue to follow up with the patient going forward. In rural areas, the face-to-face encounter also may be conducted via telehealth services as long as other program requirements are met for telehealth.

Medicare Home Health Face-to-Face Requirement Medicare’s Hospice Benefit: Eligibility, Election, & Duration of Benefits

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The most important things to remember are that both the certification and the documentation of the face-to-face encounter must be prepared and dated by the certifying physician, and the certification must be signed by the certifying physician. Physicians and home health agencies should note that the face-to-face encounter only is required for the initial certification and not for any subsequent recertification. At the same time, some of that is also not hardwired into the regulations for home health care, adding further confusion for providers. Face-to-face documentation is already one of the top reasons for those claim denials in Medicare and Medicaid, and also, the regulatory guidelines have recently changed – a further reason why providers need to hone in on best practices.

Home Health Special Open Door Forum (SODF) Documents

"Wound care completed to left great toe. No s/s of infection, but patient remains at risk due to diabetic status. Skilled nurse visits to perform wound care and assess wound status. Patient on bed to chair activities only." You can use the clinical templates or suggested clinical data elements to assist with documenting the Plan of Care/Certification and face-to-face encounter to support the need for home health services. USLegal has been awarded the TopTenREVIEWS Gold Award 9 years in a row as the most comprehensive and helpful online legal forms services on the market today. TopTenReviews wrote "there is such an extensive range of documents covering so many topics that it is unlikely you would need to look anywhere else". If a home health patient dies shortly after admission to an HHA, but before the face-to-face encounter occurs, the certification is deemed complete as long as the contractor determines a good faith effort was made by the HHA to arrange the face-to-face encounter and all other certification requirements are met.

The initial certification must include documentation that an allowed physician or non-physician practitioner had a face-to-face encounter with the patient. The FTF encounter must be related to the primary reason for the home care admission. Without a complete initial certification, there cannot be subsequent episodes. It is common for a hospitalist or physician who cared for a patient and has privileges at an acute or post-acute facility to directly refer the patient for home health services, initiate orders and a plan of care, and certify the patient’s eligibility. In this scenario, however, the facility physician is expected to identify the community physician who will be assuming primary care responsibility for the patient upon discharge. It may also be performed by a physician who cared for the patient in an acute or post-acute facility directly prior to the home health admission, and who has privileges at the facility.

Dates are supposed to be included in the body of the certification language theoretically, but back in 2015, questions rose on how EMRs would factor into that. Centers for Medicare & Medicaid Services published a list of FAQs, which did say that CMS has intended that to be the case. Before sharing sensitive information, make sure you’re on a federal government site.

Also, this encounter must be performed by a physician or a permissible non-physician practitioner , i.e., an advanced practice nurse or physician assistant. If an NPP performs the face-to-face encounter, the practitioner must document the clinical findings and communicate those findings to the certifying physician. The documentation of the face-to-face encounter must be a separate and distinct section or addendum to the certification, and must be signed and dated by the certifying physician.

Effective Jan. 1, a certifying physician or qualified non-physician practitioner must document that he or she had a face-to-face encounter with a patient who requires home health services no more than 90 days prior to the start of care or within 30 days after the start of care. A second face-to-face encounter is required within 30 days after the start of care if the patient’s condition changes from what was documented in the visit made 90 days prior to start of care, and a change in treatment is required. The Affordable Care Act established a face-to-face encounter requirement for certification of eligibility for Medicare home health services, by requiring the certifying physician to document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care.

The responsibility for the content of this file/product is with CGS or the CMS and no endorsement by the AMA is intended or implied. The AMA disclaims responsibility for any consequences or liability attributable to or related to any use, non-use, or interpretation of information contained or not contained in this file/product. CMS has indicated that it will issue instructions to its contractors with regard to medical reviews and program integrity activities. These contractors will be tasked with making sure that providers are complying with the required time frames set forth for the face-to-face encounters. CMS also has indicated that partial payments will not be made if the face-to-face encounters are performed outside the required time frames.

The Center for Medicare Advocacy produces a range of informative materials on Medicare-related topics. Home Health Care News is the leading source for news and information covering the home health industry. This event explores the strategies for deals, investments and transactions in the home health, home care, hospice and palliative care space. Seamlessly supplement your clinical assessments with CareScout’s nationwide network of 35,000+ registered nurses. However – especially for providers working under the Review Choice Demonstration – this is not always a valid reason for a denial, according to Harder. The rules and regulations around it are often inconsistent, but there are also ways for providers to fight back against claim denials.

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Also, if a patient elected to be discharged from home care services or was discharged with goals met and/or no expectation of return to home care, a future initiation of home care would trigger a new certification, a new start of care, and the need for a new F2F encounter. Acceptable FTF documentation does not have to be lengthy or overly detailed. However, the FTF documentation must show the reason skilled service is necessary for the treatment of the patient's illness or injury, based on the physician's clinical findings during the face-to-face encounter, and specific statements regarding why the patient is homebound. Noncompliance with the recently enacted face-to-face certification requirements is one of the newest compliance risk areas that could lead to denials in future audits for home health agencies.