May 27, 2016
Home Health Face-to-Face Documentation
Based on the most recent Comprehensive Error Rate Testing (CERT) error report, CGS continues to see errors where the face-to-face (FTF) documentation does not support the patient's homebound status and/or medical necessity. Please review the following information to help reduce these types of errors.
- Documentation in the certifying physician's medical records and/or the acute/post-acute care facility's medical records is used to determine the patient's eligibility for Medicare home health care.
- To be eligible, a physician must certify that the patient meets the following requirements:
- Confined to the home;
- Under the care of a physician or allowed provider
- Services are provided under a plan of care established and periodically reviewed by a physician or allowed provider;
- Be in need of skilled nursing care on an intermittent basis or physical therapy or speech-language pathology; or
- Have a continuing need for occupational therapy.
Although the home heath agencies (HHAs) documentation is not used to demonstrate the patient's eligibility, the HHAs documentation can be incorporated into the certifying physician's medical record and used to help support the patient's homebound status and need for skilled care. HHAs are encouraged to send documentation to the physician at the same time the certification is sent to be signed. Such HHA documentation may include, the admission summary, part of the Outcome and Assessment Information Set (OASIS), therapy evaluation or therapy notes, and nurse's notes. This information must be corroborated by other medical record entries in the certifying physician's medical record. The certifying physician must sign off on the HHAs documentation, prior to submitting the claim.
Refer to the resources below for additional information:
- Medicare Benefit Policy Manual (CMS Pub. 100-02, Ch. 7, §30.5.1.1)
- Face-to-Face (FTF) Encounters for Home Health Certification Quick Resource Tool
- Home Health Denial Fact Sheet: 5HC01 – Missing/Incomplete/Untimely Face-to-Face Encounter Quick Resource Tool
- Home Health Face-to-Face (FTF) Encounter Web page
- Missing Home Health Face-to-Face Encounter Documentation – February 2016 HHH Bulletin article (page 3)
Please share this information with your appropriate staff.