{"id":74,"date":"2018-03-22T15:55:28","date_gmt":"2018-03-22T15:55:28","guid":{"rendered":"https:\/\/advantagehcconsulting.com\/blog\/?p=74"},"modified":"2018-03-22T16:13:13","modified_gmt":"2018-03-22T16:13:13","slug":"medical-review-use-these-8-pointers-to-defend-your-claims-against-f2f-cert-denials","status":"publish","type":"post","link":"https:\/\/advantagehcconsulting.com\/blog\/2018\/03\/22\/medical-review-use-these-8-pointers-to-defend-your-claims-against-f2f-cert-denials\/","title":{"rendered":"Medical Review: Use These 8 Pointers To Defend Your Claims Against F2F & Cert Denials"},"content":{"rendered":"

\"\"<\/h4>\n

Will new F2F clinical template help you?<\/em><\/strong><\/span><\/h4>\n

Scrutiny of your claims is heavier than ever, and physician certification \u2014 including the face-to-face encounter \u2014 is a hot target for reviewers.<\/p>\n

Inadequacy of physician documentation is a longstanding issue in home health, notes consultant\u00a0Joe Osentoski\u00a0<\/strong>with\u00a0QIRT\u00a0<\/strong>in Troy, Michigan. \u201cThere is no \u2018magic bullet\u2019 to address this problem,\u201d Osentoski acknowledges. But HHAs can take productive steps to protect their claims against denials based on physician documentation.<\/p>\n

Check out the experts\u2019 top advice to combat the widespread, reimbursement-threatening problem:<\/p>\n

    \n
  1. Know the basics.<\/span>\u00a0<\/strong>Medicare and HHH Medicare Administrative Contractors have laid out the elements they expect to find in the physician certification documentation, including to support the F2F encounter. Those elements range from the physician dating the F2F encounter to explaining why the patient is homebound. Go to the source to see what Medicare and its contractors expect of you.<\/li>\n
  2. Educate referral sources.<\/span>\u00a0<\/strong>If physicians can\u2019t support their patients\u2019 need for home care services in their documentation, agencies can\u2019t accept the patients and they won\u2019t be able to access home care services.<\/li>\n<\/ol>\n

    Use tools provided by CMS and the MACs to educate physicians and their office staff, advises clinical consultant\u00a0Anna Doyle\u00a0<\/strong>with\u00a0McBee Associates\u00a0<\/strong>in Hilton Head, South Carolina.<\/p>\n

    \u201cProviding your referring physicians with the educational materials is a necessary first step,\u201d\u00a0Palmetto GBA\u00a0<\/strong>Medical Director\u00a0Harry Feliciano\u00a0<\/strong>said in response to an HHA commenter on one of the MAC\u2019s educational posts about the requirements.<\/p>\n

    \u201cA thorough understanding of how your top referral sources create their F2F documentation, however, is the next step. By studying the actual steps taken by your major physician referral sources to identify, document, and communicate the functional status information necessary to meet the F2F requirement, your organization will gain insight as to the processes that need to be revised in order to prevent future denials,\u201d the physician suggested.<\/p>\n

    Consider:<\/span>\u00a0<\/strong>HHAs may want to use CMS\u2019s new version of the draft clinical templates or suggested clinical data elements (CDEs) for F2F encounters, which the agency issued last month, Osentoski points out. CMS also issued a draft template and CDEs for the Plan of Care\/Certification last September.<\/p>\n

    This is CMS\u2019s second attempt to develop a clinical template that would support the eligibility criteria for home health patients, notes the\u00a0National Association for Home Care & Hospice<\/strong>. CMS issued a draft template in 2015 that was roundly criticized and never finalized.<\/p>\n

    Drawback:\u00a0<\/strong><\/span>Industry experts have complained that the F2F template is much too long for physicians to utilize as a stand-alone form and requires many more details than a doc usually records. Attendees of a March 1 Special Open Door Forum on the template and CDEs raised this issue again with CMS and offered numerous suggestions for improvement, NAHC reports.<\/p>\n

      \n
    1. Provide the requirements and the examples.<\/span>\u00a0<\/strong>While providing the outlines of what\u2019s required for the certification \u2014 the five points the\u00a0Centers for Medicare & Medicaid Services\u00a0<\/strong>outlines in\u00a0MLN Matters\u00a0<\/em>article SE 1436 \u2014 is important, you\u2019ll likely see better results if you also provide multiple examples of what good certifications and supporting documentation look like, experts say. That\u2019s where educational articles from the MACs come in handy (see box, p. 85<\/em>).<\/li>\n
    2. Double-check the F2F date.<\/span>\u00a0<\/strong>\u201cThe certifying physician must also document the date of the face-to-face encounter,\u201d CMS notes in\u00a0MLN Matters\u00a0<\/em>article SE 1436. But MAC\u00a0CGS\u00a0<\/strong>\u201chas observed many physician certifications do not contain a statement for documenting the date of the face to face encounter,\u201d it says on its website. Be sure to check this technical detail before you bill.<\/li>\n<\/ol>\n

      \u201cIf the certifying statement on the plan of care does not contain the F2F encounter date, provide a separate form to the MD to sign identifying the date of the encounter,\u201d counsels consultant\u00a0Pam Warmack\u00a0<\/strong>with\u00a0Clinic Connections\u00a0<\/strong>in Ruston, Louisiana.<\/p>\n

        \n
      1. Get the physician documentation \u2014 every time.<\/span>\u00a0<\/strong>\u201cIf the [physician or facility] documentation used as the basis for the certification of eligibility is not sufficient to demonstrate that the patient is or was eligible to receive services under the Medicare home health benefit, payment will not be rendered for home health services provided,\u201d CMS warns in the\u00a0MLN Matters\u00a0<\/em>article.<\/li>\n<\/ol>\n

        Key:<\/span>\u00a0<\/strong>\u201cThe certifying physician\u2019s and\/or the \u2026 facility\u2019s medical record for the patient must contain the actual clinical note for the face-to-face encounter visit that demonstrates\u201d the requirements, CMS stresses.<\/p>\n

        Don\u2019t just operate on blind faith that the physician documentation will be up to snuff if you need it. \u201cWe\u00a0must\u00a0<\/em>secure the face-to-face encounter documentation from the physician or facility ourselves for our own charts,\u201d Warmack stresses.<\/p>\n

        Tip:<\/span>\u00a0<\/strong>\u201cIn addition to the actual clinical note for the face-to-face encounter visit, any documentation from the physician\u2019s or \u2026 facility\u2019s medical records can be used to help justify\/substantiate the need for home health services and homebound status,\u201d offers HHH Medicare Administrative Contractor\u00a0National Government Services\u00a0<\/strong>in a tips sheet generated from Probe &amp; Educate denials. \u201cInclude in your submitted documentation any recent \u2026 facility therapy notes, social work or discharge planning records, history &amp; physicals, and other clinical progress notes.\u201d<\/p>\n

          \n
        1. Make sure your documentation is signed in \u2014 every time.<\/span>\u00a0<\/strong>Don\u2019t count on the physician record alone to defend your claim against certification and F2F scrutiny. \u201cProvide to physicians and referring facilities the documentation from agency assessments and plans of care,\u201d advises\u00a0Beth Noyce\u00a0<\/strong>with\u00a0Noyce Consulting\u00a0<\/strong>in Salt Lake City.<\/li>\n<\/ol>\n

          \u201cInformation from the HHA, such as the patient\u2019s comprehensive assessment, can be incorporated into the certifying physician\u2019s and\/or \u2026 facility\u2019s medical record for the patient,\u201d CMS explains in the\u00a0MLN Matters\u00a0<\/em>article. However, keep in mind that \u201cinformation from the HHA must be corroborated by other medical record entries and align with the time period in which services were rendered,\u201d CMS says.<\/p>\n

          Also, \u201cthe certifying physician must review and sign off on anything incorporated into the patient\u2019s medical record that is used to support the certification of patient eligibility (that is, agree with the material by signing and dating the entry).\u201d<\/p>\n

          Warning:<\/span>\u00a0<\/strong>\u201cA blanket form signed by the certifying physician will not suffice to meet the regulations in lieu of signing off on the particular pages being incorporated,\u201d CGS says on its website.<\/p>\n

          And \u201cthe home health documentation being incorporated would be expected to corroborate or match and should not contradict the certifying physician\u2019s documentation,\u201d CGS says.<\/p>\n

          \u201cAlways submit to the physician documentation from your assessments or findings and request that the certifying physician sign it and incorporate it into his\/her clinical records,\u201d Warmack recommends. \u201cMy clients have been doing so since January 2015 and have had good success with this practice.\u201d<\/p>\n

            \n
          1. Educate your own clinicians.<\/span>\u00a0<\/strong>While it\u2019s good news that you can get your documentation signed into the physician record to defend against cert\/F2F denials, it underscores the importance of your own clinical documentation.<\/li>\n<\/ol>\n

            \u201cThe majority of providers \u2026 continue to be confused about where and how to document eligibility for home health,\u201d Doyle laments. \u201cHome health compliance and subsequent payment for reasonable and necessary services cannot rely on physician documentation in their own records\u201d \u2014 your documentation needs to boost your docs\u2019.<\/p>\n

            \u201cRe-educate clinicians how and where to document eligibility,\u201d Doyle instructs. This may include working with the electronic medical record if possible \u201cfor clinicians to document eligibility for home health services in a specific and standardized area (i.e., a field for specific homebound status narrative and a field for attestation of F2F encounter date and\/or collaboration as applicable on the 485),\u201d she adds.<\/p>\n

            HHAs should go \u201cto the basics of clearly understanding what is required, ensuring agency staff and quality assurance\/review staff have this knowledge,\u201d Osentoski recommends.<\/p>\n

              \n
            1. Audit yourself.\u00a0<\/strong><\/span>Before medical reviewers take a whack at your claims, make sure you\u2019ve given them your own third-degree.<\/li>\n<\/ol>\n

              Your documentation process should begin with \u201cchecking content of the record at time of admission\u201d and then \u201cpursuing acquisition of sufficient content from the physician to meet the requirement,\u201d Osentoski says. But that\u2019s not the end of it.<\/p>\n

              \u201cChecking compliance before final billing is done will yield the most chance of improvement,\u201d Osentoski tells\u00a0Eli<\/strong>. \u201cBest practice is to at least check the record at start of care and before billing that first episode to reduce chances of problems.\u201d<\/p>\n

              Tool:<\/span>\u00a0<\/strong>Use CGS\u2019s prebilling documentation checklist to help make sure your record is complete:\u00a0www.cgsmedicare.com\/hhh\/education\/materials\/pdf\/hh_documentation_checklist_tool.pdf<\/a>.<\/p>\n

              If you have any question book a call here for a free consultation:<\/span> Advantage Healthcare Consulting<\/a><\/span><\/p>\n

              Source- SuperCoder<\/a><\/p>\n","protected":false},"excerpt":{"rendered":"

              Will new F2F clinical template help you? Scrutiny of your claims is heavier than ever, and physician certification \u2014 including the face-to-face encounter \u2014 is a hot target for reviewers. … Continue Reading →<\/a><\/p>\n","protected":false},"author":1,"featured_media":75,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[8,6],"tags":[11,12,13],"class_list":["post-74","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-compliance","category-medical-review","tag-home-care","tag-hospice","tag-ltc"],"_links":{"self":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/74","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/comments?post=74"}],"version-history":[{"count":2,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/74\/revisions"}],"predecessor-version":[{"id":97,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/74\/revisions\/97"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media\/75"}],"wp:attachment":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media?parent=74"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/categories?post=74"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/tags?post=74"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}