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August 9, 2018

Medical Review of Face-to-Face Encounter Documentation

As of January 1, 2015, CGS began reviewing home health claims for the face-to-face (FTF) encounter documentation for all home health episodes, including the start of care (SOC) episode and all subsequent episodes. Prior to January 1, 2015, CGS only reviewed initial start of care episodes for the FTF documentation. However, because the FTF documentation is a requirement for Medicare payment, all additional development requests (ADRs) for home health claims now must include the FTF documentation. To clarify, FTF documentation (for SOC and subsequent episodes) would include, but not be limited to, submitting the actual clinical notes (i.e. discharge summary/history and physical/progress notes, or physician office visit note), for the primary reason the beneficiary was referred to homecare. Additionally, included in determining appropriateness of the FTF documentation, the initial home health SOC plan of care, along with any certifying physician's attestations, must be submitted with every episode. Claims may be denied if the FTF documentation is not submitted or is incomplete.

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