Home Health & Hospice

April 1st Brings More Than April Fools' Day

Homecare Insider, March 28, 2011

The date that providers have been dreading has quickly approached. On April 1, the Centers for Medicare and Medicaid Services (CMS) will begin enforcement of the new home health face-to-face physician encounter and therapy assessment and documentation requirements. Providers should be ready to comply and face the obstacles that may plague them, especially in regard to the face-to-face physician encounter. CMS has instructed providers to treat episodes that lack a face-to-face physician encounter within the required time period as they would those that lack a signed certification.

At the time of admission, agencies should include the face-to-face encounter in their notice of rights and responsibilities given to patients and list it as a patient responsibility. Along with this, admitted patients who have not yet had the encounter should be educated, at that time, about the requirement and the timeframe. The discharge policy, should the patient fail to have the encounter, needs to be explained in detail at this time as part of this education. Agencies should assist in making this physician encounter happen even going as far as making the appointment for them if necessary. 

Providers must also protect themselves by putting their intended course of action into policy should the patient fail to have the required encounter, including the notice they will give to patients in case of discharge. It’s important for agencies to remember that usually state rules govern the advance notice they must give to patients prior to discharge. CMS is now allowing providers to utilize the Home Health Advance Beneficiary Notice (HHABN) Option Box 2 to notify patients of the termination of services related to their failure to have the required face-to-face physician encounter. Agency policy should also include language which states that the agency will provide a referral to another provider and give patients a choice of that provider.

In order to enlist physician cooperation, education should be ongoing, with new physicians and referral sources educated along the way. Physicians and referral sources must also be educated on your discharge policy should the encounter fail to occur. It’s important that physicians and referral sources understand the effect that this encounter, or the lack thereof, has on your agency. 

Still struggling with understanding the face-to-face physician encounter requirements? Let Beacon Health help you make sense of this confusing requirement as well as how to provide and document therapy services appropriately. Learn more today!