Case Management

Customized physician order streamlines the face-to-face requirement but doesn't guarantee physician cooperation

Case Management Monthly, July 1, 2011

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From the Important Message from Medicare to the discharge instructions, case managers juggle a myriad of forms throughout a patient stay. CMS added another form to the list when it implemented the face-to-face encounter requirement for home health referrals.

According to the 2011 home health prospective payment system final rule, a physician or an allowed nonphysician practitioner (NPP) must have a face-to-face encounter with a Medicare beneficiary prior to a home health referral in order to qualify for reimbursement. The encounter can occur either 90 days before the patient begins home healthcare services or 30 days after discharge from the hospital.

The allowed NPPs are nurse practitioners, clinical nurse specialists, and certified nurse-midwives. Case managers are not in that list, which means facilities where case ­managers order home healthcare services must adapt, says Frank L. Urbano, MD, FACP, medical director of care coordination and attending physician at Cooper University Hospital in Camden, NJ.

Before the face-to-face regulation, hospital case managers at Cooper University assessed each patient's discharge needs. If they determined that the patient needed home healthcare services, the case managers would order a consult. Now physicians must make that ­determination, and the shift in practice has not been an easy one, ­Urbano says. Some physicians have had a hard time getting used to the new responsibility, while ­others ­simply do not see the value. The result is that some patients have been discharged without a home health referral.

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