Beginning April 1 2011, Medicare homecare patients are required to have a documented face-to-face encounter with either a physician or a non-physician provider. This encounter can either occur 90 days prior to the start of the homecare encounter or within 30 days after the start of care. But the encounter has to be related to why they need homecare services.
This documentation has been a huge challenge for homecare agencies across the country. Agencies are already seeing a decrease in referrals and patients that would benefit from homecare are not able to access the care because of the burden of the regulation.
The reasons for this challenge to homecare agencies include:
- The documentation from the providers have to be in their words. Agencies can create forms, however, they are not to use pre-populated fields such as check boxes. This is especially challenging when the provider has to document why the patient is homebound. The vast majority of providers do not understand the CMS definition and the significant importance that CMS puts on the homecare agency to document this.
- Many providers are already faced with additional requirements and with lower reimbursement to achieve them. Agencies are getting significant push back from providers to complete these forms. Providers are asking for the agency to complete the form so that the provider can just sign off. The regulation specifically does not allow this. So some providers are just refusing to complete this documentation. Agencies then have to discharge the patient from services. Regulation specifically exempts the patient from financial liability if the documentation is not complete. The agency cannot bill for any services provided.
Please spread the word and ask physicians to fill out this quick yet important survey from NAHC. If you would like a hard copy, please email me at firstname.lastname@example.org.
Thanks in advance for your help.