Home Health Face-To-Face (FTF) Encounters FAQs
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- What is meant by the actual clinical note that must be submitted in the documentation?
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The actual clinical note is the physician's documentation to show he/she actually saw the patient. It will include such things as vital signs, weight, and specific comments from the examination.
New: 03.27.17
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- If a physician uses and signs his or her own FTF document, are we to accept it as meeting requirements, irrespective of the content or correctness of the content?
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Regardless of whether the physician uses a hospital-created form or their own document, Home Health Agencies (HHAs) are still responsible to ensure the content of the FTF documentation meets Medicare requirements.
Reviewed: 03.27.17
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- A patient had a scheduled appointment on day 26 of the 30 days after the start of care (SOC). The physician cancelled the appointment due to a family emergency. The following Monday, (day 30) was a holiday; again not a situation over which the HHA has any control. What should be done in cases like this?
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The HHA has always been required to coordinate with the patient's physician to obtain a signed care plan, to update the care plan as needed, and to obtain a completed certification. The face-to-face encounter is an additional certification content requirement, and the HHA is expected to coordinate with the physician and patient to ensure compliance.
HHAs are responsible to ensure they are able to obtain the required documentation prior to billing Medicare.
Reviewed: 03.27.17
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- If skilled nursing (SN), physical therapy (PT) and occupational therapy (OT) are all ordered disciplines, does each discipline need to be addressed separately on the FTF document. Is it sufficient to meet the standard for justifying home health care through one discipline?
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It is not necessary to address each discipline individually. At least one qualifying skilled service must be clear, such as "Patient needs skilled nursing to perform wound care to stasis ulcer", any additional disciplines would be allowed in medical review.
Reviewed: 03.27.17
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- Does the patient meet homebound criteria if the statement by the physician indicates that they are 'medically restricted', immunocompromised' or at 'high risk of infection' or does the statement still need to indicate that the patient needs assistance of another person/device to exit the home?
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None of the statements, including 'patient needs assistance of another person/device to exit the home' are sufficient to support the beneficiary's homebound status. The face to face documentation must explain specifically why the findings from the encounter support the beneficiary's homebound status.
Reviewed: 03.27.17
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- If an individual is at 'high risk for falls' and sustained a fracture due to a recent fall is that sufficient for homebound documentation?
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The face to face documentation must explain why the findings from the encounter support the beneficiary's homebound status. The statement 'at high risk for falls' would not be sufficient.
Reviewed: 03.27.17
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- If the agency sends the physician a FTF form and he returns to the agency a clinic note signed and dated with all the correct data from our FTF form, can we accept as FTF form?
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CMS does not require a specific form or format to be used for the FTF. As long as the FTF encounter documentation contains all content requirements the HHA could use the clinic note.
Reviewed: 03.27.17
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- Does a face-to-face encounter form need to be completed every time a patient is recertified, or only the first time they are admitted to a home health agency?
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The HH face-to-face encounter is only mandated at the SOC, not upon each recertification. (CMS Q&A 29
)Reviewed: 03.27.17
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- Do FTF documents need to be obtained for patients with Medicare Secondary Payer (MSP) records?
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The home health FTF encounter is a condition for Medicare payment. Therefore, if the HHA will be billing Medicare for full or partial payment for the services they will be providing to the patient, the FTF encounter must be completed and documented.
Reviewed: 03.27.17
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- A referral received on Friday requested home health services with physical therapy to begin on Monday. The patient had a total knee replacement on Friday. The surgeon conducted the face-to-face, but declined to sign orders or follow the patient after hospital discharge. The primary care physician (PCP) had seen the patient 10 days prior for the pre authorization physical. The PCP was contacted on Friday but was out of the office until Monday. How can services begin on Monday?
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The surgeon completed the face-to-face encounter, and can write orders to see the patient and conduct the physical therapy evaluation. This would allow the agency to go see and admit the patient. A plan of care can be created to include the orders for physical therapy. The plan of care would then be sent to the primary care physician for review and signature.
Reviewed: 03.27.17
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- If the physician is signing a multiple page Center for Medicare and Medicaid Services (CMS) form 485, does the physician have to sign every page to be considered as reviewed and approved by the physician?
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With a multiple page document, each page should be identified as being part of the entire document. For example; page 1 of 4, page 2 of 4, page 3 of 4 and page 4 of 4. The physician is aware he/she is signing the entire document and only needs to affix their signature to one page of the document.
Reviewed: 03.27.17
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- Can you give an example of home health documents not conflicting with documents in the physician's medical record?
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For example, the physician's encounter document notes the patient was able to ambulate without difficulty. The home health agency summary notes balance issues and painful ambulation.
Reviewed: 03.27.17
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- The physician certification must be signed prior to billing. Does that mean that final claim or before the RAP also?
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The physician certification must be signed before the final claim is submitted. The RAP can be billed before the certification is signed.
Reviewed: 03.27.17
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- Is CMS form 485 required for the physician certification?
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The 485 is not a required form, but is used frequently by home health agencies.
Reviewed: 03.27.17
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- What should the physician certification include?
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The physician certification should state the patient is confined to their home, needs skilled services, a plan of care is established and periodically reviewed and that the patient is under the care of a physician.
Reviewed: 03.27.17
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- When does the hospitalist need to identify the community physician who will be following the patient?
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If the hospitalist certifies the patient for home health but will not follow the patient after discharge, he/she must identify the community physician who will follow the patient.
Reviewed: 03.27.17
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- The hospitalist completed the face-to-face, but will not be the certifying physician. Does the certifying physician also have to cosign the hospitalist's face-to-face encounter?
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The certifying physician does not need to cosign the face-to-face document. The certifying physician just needs to have the date the face-to-face encounter was completed.
Reviewed: 03.27.17
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- What does the certifying physician need to do if another physician or allowed non-physician practitioner (NPP) performs the face-to-face encounter?
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The certifying physician must document the date of the encounter. This can be achieved by the certifying physician including a statement documenting the date of the encounter OR by co-signing the face-to-face document.
Reviewed: 03.27.17
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- If we get a face-to-face for the initial episode, then do we need to get another face-to-face for every recertification, or just the clarification from the physician for additional visits for the next certification period?
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There only needs to be a face-to-face encounter if there's a need for a start of care (SOC) Oasis.
Reviewed: 03.27.17
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- Can I use the face-to-face forms we have been using?
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There are no specific forms required for face-to-face documentation. The encounter note from the physician is required. Your face-to-face form that you used to use is optional.
Reviewed: 03.27.17
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- If the patient visits the doctor within 90 days prior to the start of care and the reason for the visit relates to the home health services provided, do we need to get another face-to-face encounter completed?
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No, as long as the visit is timely and is focused on the reason for home health services, another face-to-face visit is not required.
Reviewed: 03.27.17
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- What if the face-to-face encounter did not discuss the patient's homebound status?
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You are able to submit additional documentation such as the start of care OASIS, to supplement medical records, including the homebound status of the patient.
Reviewed: 03.27.17
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- A progress note is prepared by the home health agency for the physician to sign along with his/her estimate of time the patient will qualify for home health services. If the recertification period is for 60 days and the physician estimates four more weeks of service, does that mean the orders for 60 days are disregarded?
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No, the physician estimate is not a concrete period of time. You do not need to get orders for the remaining four weeks to match the estimate unless the patient is actually still qualified for home care at the end of the four week orders.
Reviewed: 03.27.17
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- If the provider receives outstanding documentation and a copy of the encounter note, but the encounter note is nothing more than three sentences, does that meet requirements?
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If both the documentation and the copy of the encounter note meets all the requirements. CGS is able to look at anything within the patient's medical record from the acute or post acute care facility, as well as any documentation submitted from the agency, as long as the certifying physician adds is into their medical record that corroborates the overall findings.
Reviewed: 03.27.17
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- Is the physician estimate of time the patient will qualify for home health services required at the time of recertification or also required at the start of care?
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The physician estimate is required only at recertification, not at the start of care.
Reviewed: 03.27.17
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- Can a resident perform and sign the home health face-to-face encounter?
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The physician and not the resident must sign the home health plan of care. The resident working under their physician could perform the face to face; however, the physician must sign the plan of care.
According to the Medicare Benefit Policy Manual, Pub. 100-02, Ch. 7 §50.5
, home health services include the medical services of interns and residents-in-training under an approved hospital teaching program if the services are ordered by the physician who is responsible for the plan of care and the HHA is affiliated with or is under common control of a hospital furnishing the medical services. Approved means:- Approved by the Accreditation Council for Graduate Medical Education;
- In the case of an osteopathic hospital, approved by the Committee on Hospitals of the Bureau of Professional Education of the American Osteopathic Association;
- In the case of an intern or resident-in-training in the field of dentistry, approved by the Council on Dental Education of the American Dental Association; or
- In the case of an intern or resident-in-training in the field of podiatry, approved by the Council on Podiatric Education of the American Podiatric Association.
Reviewed: 03.27.17
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- If the face-to-face form includes information from the visit, is the encounter note still required?
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The encounter note from the face-to-face encounter must always be submitted.
Reviewed: 03.27.17
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- Does the certifying physician need to co-sign the face-to-face form?
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No, the certifying physician does not have to co-sign the face-to-face form. However, the certifying physician must document the date of the face-to-face encounter, whether by co-signing the face-to-face form OR including the date of the face-to-face encounter on the certification form.
Reviewed: 03.27.17
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