Home Health & Hospice

Almost one-third of face-to-face encounters did not have documentation to meet Medicare requirements

Homecare Insider, April 28, 2014

An April 2014 report by the Department of Health and Human Services (HHS) Office of Inspector General (OIG) has found that 32% of home health claims involving face-to-face encounters did not have sufficient documentation to meet Medicare’s requirements, resulting in $2 billion in payments that should not have been made. The OIG also found that physicians did not complete the narrative portion of the face-to-face consistently.
The OIG recommends that the Centers for Medicare & Medicaid Services (CMS) requires a standardized face-to-face form, something CMS has already responded too, releasing an Electronic Clinical Template for Physicians. The OIG also recommends that CMS develop a strategy to communicate face-to-face requirements with physicians and develop additional oversight mechanisms.
The study found that face-to-face documentation lacked the signature of the certifying physician 17% of the time. It also found that some face-to-face documents contained helpful, but not required elements, such as physician NPIs, printed name of the physician, name of the non-physician practitioner, letter of the home health agency or hospital, and a list of home health series needed.