The Public Health Emergency has resulted in some changes to the face-to-face encounter guidelines, but F2F has not gone away! As agencies in Review Choice Demonstration states navigate Pre-Claim Review, Palmetto is answering questions and offering additional suggestions on meeting the F2F requirements.
If you are struggling with pre-claim review in a current RCD state (Illinois, Ohio and Texas), if you want to avoid future problems with ADRs, or if you just want to make sure you are doing everything by the book, here are some tips.
The F2F encounter documentation requirements
- Requires the actual encounter visit documentation, usually an office visit note, an inpatient progress or consult note or discharge H&P/summary
- Must include the date the F2F visit occurred, name of the provider who performed the visit, the reason the patient needs home care services,
- Must be signed and dated by the provider who performed the encounter visit
- Must describe how the patient’s clinical condition during that encounter supports the patient’s homebound status and the need for skilled home care services
- The reason for the visit must be related to the reason the patient requires home care services
- Under the PHE, effective March 29, 2020, the F2F encounter visit may be done via telehealth in accordance with these requirements: must be via an audio and visual format that allows two-way real time communication between provider and patient (such as Skype, Zoom or other similar method; phone only does NOT meet this requirement)
- NOT a form the agency completes or gives the provider to complete (a F2F form may supplement the original F2F encounter note, but the physician has to sign it)
Addendum to the F2F
If the F2F encounter does not contain clear documentation to meet ALL F2F requirements, the agency may send additional information to the certifying provider to support the F2F requirements. For example, the F2F may not have complete documentation of homebound status to meet Criteria 1 and Criteria 2 of the homebound eligibility requirement.
- Agency may send information from their assessment, evaluations, case conferences or care coordination notes, and other information from the acute or post acute facility clinicians/staff.
- Information should not conflict with any other documentation within that time period
- Certifying provider must review and sign off on anything incorporated into the patient’s medical record used to support F2F requirements
- Additional documentation must be signed off prior to the time the claim is submitted (and prior to submission for pre-claim review if you are under RCD)
- Agency may use a supplemental form to organize the additional information, or may include this additional information specifically labeled on the Plan of Care (485) itself
Tips from Palmetto RCD teleconferences sponsored by TAHC&H
- The certifying provider must acknowledge the F2F encounter by documenting it either on the certification, which the provider signs and dates, or on a signed addendum to the certification which must be signed and dated by the certifying provider (which must be a physician or allowed non-physician provider). This certification statement must include the date of the F2F encounter visit, the name of the person who performed the visit, and the date the certifying provider signs to accept the F2F as valid.
- If the person who did the F2F encounter visit is also the certifying provider for home care services, no separate attestation statement is necessary, although we recommend that the acknowledgment be included to include any supplemental information.
- If the certifying provider is different from the F2F encounter provider, the certifying provider must acknowledge the F2F encounter document itself, usually by signature OR must have a certification statement on the POC as described above.
- Nothing prohibits the F2F encounter visit from being done prior to surgery. A pre-op visit 3 days before surgery for a patient with OA of the left knee and a planned total knee replacement is acceptable. As always, if all F2F requirements are not met in the documentation of the encounter visit, the agency may send the certifying provider additional information to support the F2F requirements.
- Not acceptable as the F2F encounter: the actual operative note (example: physician noted “the patient was not awake for F2F”).
- Selection of the primary diagnosis on the POC may be affected by coding guidance that has mandatory sequencing: HH agencies must follow coding guidance (per HIPAA). With that said, some coding guidance is inconsistent with home health payment realities. For example, coding “dementia” and “hypothyroidism” as an assumed linkage due to “with” guidance – if the physician does not identify the type of dementia. Dementia should be coded as unspecified (F03.-) and not listed under Hypothyroidism as a secondary dementia (F02.-)
- If the patient had surgery and is referred to home care for “Aftercare” and the F2F documentation includes the reason for the surgery, the Aftercare code may be the primary diagnosis on the POC. The agency should provide additional documentation to support the patient’s homebound status and need for skilled care after surgery based on the SOC assessment or additional documentation including the physician or NPP signature.
- If the agency’s focus of care (primary diagnosis on the POC) is not listed as the reason for home care referral, or the F2F visit is not related to the reason for home care services, BUT the diagnosis or condition is mentioned in the F2F encounter visit documentation, agency may do a query statement and have the physician sign off on changing the sequencing of diagnoses. For example, the F2F encounter notes the patient was seen for diagnosis 1, 2 and 3. The agency identifies diagnosis #3 as the focus of care to list primary – do a query statement to the physician to approve the change in sequencing for the home care POC.
- If the diagnosis the agency wants to use as the primary diagnosis for the POC is not mentioned on the F2F encounter note, the agency must request a new F2F encounter.
For additional help on F2F, PCR, & more check out these resources:
- [On Demand Webinar] Face-to-Face Encounters: Fact or Fiction
- [On-Demand Webinar] Telehealth in Home Health
- [On-Demand Webinar] Telehealth in Hospice
- Need help with ADRs, PCR, and more? Contact us today!
Click here for Part 2 of Meeting the F2F Challenge
Teresa Northcutt, BSN, RN, HCS-D, COS-C, HCS-H
Senior Associate Consultant | Selman-Holman, a Briggs Healthcare