The release of new Face to Face (F2F) compliance was meant to aid and lower the compliance burden placed on agencies. When the news was released, agencies first thought that the removal of the narrative requirement on Face to Face documentation would have been a positive step forward. However, we have now learned that the change has really only caused more confusion and stress.
CMS has been trying to clarify the rule but hasn’t really been able to provide a standardized, comprehensive answer. As of publication, CMS did issue more guidance that clarifies the overall change to Face to Face.
CMS has stated that if you continue to use the F2F form, it will supplement information received from the patient’s physician. CMS clarified that prior to billing for the patient, you must have a visit note from the patient’s physician or discharge summary. The F2F document currently used by many agencies will not provide sufficient documentation, but will substantiate the need for services in addition to a visit note or discharge summary.
If you choose to use a Face to Face form, your form should retain its current data collection fields, but without the narrative portion. Information you should include with your Face to Face form is:
- Date
- Reason for home health
- Signature of physician or non-physician practitioner (NPP) as defined by Medicare.
This further, most recent clarification seems to solidify the actual requirements and clear most of the fog. Should you have any questions, please let us know. We have a sample form available for those interested as well. It can be requested by emailing, hht@tortolanoandco.com.