Survey Results: Home Health Face-to-Face Requirements

By Nick Dobrzelecki RN, BSN
Daymarck CEO

Since the start of Medicare’s home health face-to-face (F2F) requirement on April 1, 2011, agencies have encountered significant resistance from physicians in accurately and completely filling out the F2F documentation. The F2F encounter requirement must occur 90 days prior to the admission or 30 days after the admission. The documentation cannot be completed by any employee of the home health agency. The F2F documentation can be placed on the certification form or is an addendum to it but it must be separate and distinct. It must also include the following:

1. The patient's name;
2. Date of the encounter;
3. How the patient's clinical condition as seen during the encounter supports homebound status and the need for skilled services;
4. The physician's signature (original signature, a faxed copy, copy of original document with signature or electronic signature - but not stamped signature); and
5. Date of the physician's signature.

Agencies have been trying to educate and provide providers with as much help as is possible within the law. However, the regulation is very specific and constrains home health agencies from doing any of the work for the providers. Agencies can create forms but they cannot use check boxes or drop down boxes in electronic records. If the provider creates their own form, they can use these features although this is not clear as CMS continues to change their responses this issue. Issues such as stamp signatures continue to be an issue for some agencies (page 2, http://www.cms.gov/MLNMattersArticles/downloads/MM6698.pdf).

The National Association of Home Care and Hospice (NAHC) contracted Fabrizio, Ward & Associates to collect data from a survey conducted June 16-27, 2011 among physicians who prescribe home health care.  2,490 physicians from 49 states and DC responded to the survey (1,746 online, 744 by fax); the data has been weighted by region to reflect the actual distribution of the U.S. adult population.

Survey Results
View a PDF of the entire findings.

The vast majority of physicians surveyed disapprove of the new documentation/certification requirements for home health, saying it is a lot more burdensome and want it simplified. Most physicians surveyed believe fewer patients will be referred to home health as a result of the new rules, and that there will be significant negative health consequences to patients as a result. Most physicians surveyed favor reforms that would allow existing doctor orders to satisfy the certification requirements for home health, and do away with the written narrative. Half of physicians surveyed did not favor reforms that simplified the certification paperwork but still required a face-to-face visit.


Next Steps
Questions still linger who is going to monitor this requirement. It is not likely to be addressed by state survey agencies as F2F is not a Medicare condition of participation. It is a coverage and payment policy which may be monitored by a fiscal intermediary. With this issue not being answered, there are stories of agencies completing the documentation and then having the providers just sign off. This is in clear violation of the rules. When the rules allow hospital discharge planners to help complete the form for providers but home care liaisons cannot, the lines are clearly drawn. The only thing that can be done by the industry is to police its self. Violations can be reported to the HHS fraud hotline at http://oig.hhs.gov/fraud/report-fraud/index.asp.