Open door forums are being held to discuss the use of a template to aid in fulfilling the face-to-face requirement for Medicare beneficiaries receiving home health care.

“In fiscal year (FY) 2014, the Comprehensive Error Rate Testing (CERT) program found that more than half (51.4 percent) of the home health claims were paid improperly. Of the 1308 CERT-reviewed claim lines in error, approximately 90 percent were found to have insufficient documentation errors. The Majority of these errors were due to inadequate documentation supporting the face-to-face requirement.”

On or after January 1, 2011, the face-to-face requirement is mandated by the Affordable Care Act (ACA) and is a condition for payment. The face-to-face requirement ensures that the orders and certification for home health services are based on a physician’s current knowledge of the patient’s clinical condition. As part of the certification form itself, or as an addendum to it, the physician must document when the physician or allowed NPP saw the patient, and document how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services.

To help facilitate fulfillment of the face-to-face requirement, the Centers for Medicare & Medicaid Services (CMS) is considering developing a voluntary paper clinical template that could be completed by physicians during their face-to-face examination of a Medicare patient. The template would help ensure that the face-to- face and homebound status of the patient is documented. Once a physician/practitioner has completed the template, the resulting document would become a progress note or clinic note that would be part of the medical record. It is important to note that a physician/practitioner will be the one required to complete the template and not a registered nurse such as a case manager or discharge planner.

Some important facts about the template are:

  • Physicians/practitioners will not be required to use it.
  • The use of a template is voluntary.
  • Once a physician/practitioner completes the template, the resulting document is a progress note or office note that is part of the medical record for that patient.
  • The note must contain all relevant information sufficient for patient care and sufficient for the physician/practitioner to bill for the appropriate level Evaluation and Management service.
  • The template is intended to be a “skip-template” where not all sections are relevant for all patients and therefore can be skipped.

The template discussed in this article will be made available in paper format that can be scanned and uploaded. Click to view the working template at the CMS Website.

CMS is working on an electronic clinical template. To see information about the electronic clinical template, see home health (HH) electronic clinical template. The electronic version will be coming later in the process.