Face-to-Face Encounters Headed for Closer Scrutiny

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By Terry Miller, RN 
Regulatory Advisor, McKesson

Home Health Face to Face Encounter DocumentationIn June, Medicare administrative contractor (MAC) CGS announced a widespread edit of home health face-to-face encounter documentation, the second such organization to address the issue this year.

The first was Palmetto GBA, which in May said it planned to conduct a comprehensive review of face-to-face encounter narratives after noticing an increase in overpayments for Home Health Prospective Payment System claims that it attributed to the requirement for a face-to-face encounter with the beneficiary.

Palmetto GBA is asking providers to review internal processes to verify all coverage criteria is met and well-documented. It said the documentation must include clinical findings to support the need for skilled services and give specific clinical findings to support homebound status. Palmetto gave the following examples of inadequate documentation:

  • Diagnosis alone, such as osteoarthritis
  • Recent procedures alone, such as total knee replacement
  • Recent injuries alone, such as hip fracture
  • The statement, “taxing effort to leave home” without specific clinical findings to indicate what makes the beneficiary homebound
  • “Gait abnormality” without specific clinical findings
  • “Weakness” without specific clinical findings

Following the initial announcement, Palmetto’s Dr. Harry Feliciano wrote a blog post recommending home care agencies take a structured approach to communicating a beneficiary’s functional status.

Step 1: Identify relevant structural and functional impairments and their severity.

Step 2: Identify relevant activity limitations/participation restrictions and their severity.

Step 3: Identify relevant environmental factors and their impact.

Step 4: Describe how the specific impairments of structure and function, activity limitations/participation restrictions, and environmental factors identified in steps 1 to 3 combined contribute to the beneficiary being homebound and needing skilled services.

McKesson Homecare™ home health software facilitates compliance with the home health face-to-face requirement with these features:

  • The ability to capture the status and details of the face-to-face encounter that  affect system messages and reporting functionality
  • Face-to-face visit tracking report
  • Face-to-face encounter document

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