Face to Face Compliance Updates

CMS has finalized some important changes to the way agencies must stay in compliance with F2F data gathering and timing of physician certification.

Signed Physician Certification:  Many agencies wait to hold billing until the F2F is signed by the patient’s physician.  However, under the new guidelines, agencies must continue to attempt to obtain the signed F2F during the open episode.  Billing must also be postponed until a F2F is received signed – this hasn’t changed, but just adds to the complexity and burden placed on your agency.

Physician Record: More reliance is being placed on these documents as certification of need for services.  The record provided by a patient’s physician must be able to support the need for home health services.  This requirement will come under scrutiny during medical review and should be incorporated into your Quality Policies and Procedures going forward to mitigate risk.

Recertification:  Patients deemed to be in need of continued care and additional episodes are going to be coming under special scrutiny.  CMS will be looking at whether or not the physician’s documentation supports the need for continued services and for how long home health services are needed.