The home health face-to-face physician documentation requirements have posed significant challenges for home health agency providers since January 2011. Without proper documentation within the timeframes prescribed by Medicare regulations, a home health agency cannot receive payment for a home health episode of care.
Through the last few years, the Centers for Medicare and Medicaid Services has made minor adjustments to the ways in which the requirements can be fulfilled, but the challenges have remained with many denials of payment being linked to improper or incomplete physician documentation of the clinical findings during a face-to-face encounter that support the patient’s homebound status and need for skilled services. CMS has pointed to a high level of “improper payments” under Medicare Part A for home health services as identified through the Comprehensive Error Rate Testing (CERT) program.
CMS is now proposing to pursue an electronic method for physicians to document their clinical findings to achieve consistency and completeness and will hold a series of teleconferences with stakeholders to explore this. CMS has developed a list of clinical elements within a Suggested Electronic Clinical Template that would allow electronic health record vendors to create prompts to assist physicians when documenting the home health face-to-face encounter for Medicare purposes. To bring the suggested clinical elements to the provider community, CMS is currently collaborating with the Office of the National Coordinator for Health IT and the electronic Determination of Coverage (eDoC) workgroup in developing the interoperability standards necessary for an electronic clinical template.
Click here for more information, including the draft of the electronic template and the dates for future teleconferences.
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