OIG: Face-to-Face Requirement Needs Tweaks

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Karen Utterback By Karen Utterback 
Former Vice President, Product Marketing and Strategy, McKesson (Retired)
Face to Face Requirement Needs Tweaks, OIG Says

You probably have seen the headlines about the Office of the Inspector General’s report that 32% of home health claims that required a face-to-face encounter were not completed correctly. I believe one takeaway should be the apparent difficulty that home health agencies have getting physicians to complete the documentation required by current regulations.

OIG recognized as much in the 35-page report, with two of the three recommendations aimed squarely at physicians. The OIG recommended (and CMS has concurred) that CMS should:

  • Consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation. The OIG noted that more than half of all face-to-face documents are completed using standardized forms already.
  • Develop a specific strategy to communicate directly with physicians about the face-to-face requirement. There are a couple of issues this recommendation is designed to address. The first is that the home health Medicare Administrative Contractors (MACs) are not responsible for training physicians. The second is that the physician encounter necessary to establish face-to-face eligibility is covered under Part B that may be covered by a different MAC, making claims matching difficult.
  • Develop other oversight mechanisms for the face-to-face requirement. OIG recognizes that relying on medical record reviews is insufficient to determine whether the face-to-face requirement has been met. The agency recommends that CMS work with payment contractors to develop other new procedures to ensure compliance.

The requirement that physicians write a narrative about the patient that satisfies the CMS requirements should be addressed. Given the value that home health agencies represent among healthcare providers, it should be made as easy as possible for physicians to certify patients for home health. If it were allowed, home health documentation software could help make this task easier for both physicians and agencies.

But I hope the OIG’s recommendations will make it easier for patients to receive covered home health services.

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