Who Would Have Thought!

The Affordable Care Act required physicians who certify Medicare beneficiaries to have a face-to-face encounter with the patient as part of the certification to obtain home health care.  The Office of Inspector General (OIG) for the Department of Health and Human Services did a study to determine the following

(1) Determined the extent to which physicians who certified home health care documented the face-to-face encounters, (2) Described the nature of face-to-face documentation, and (3) Assessed CMS's oversight of the face-to-face requirement.

They reviewed 644 face-to-face encounter documents to analyze the extent to which the documents confirmed encounters and contained required elements.  They also interviewed the four Home Health and Hospice Medicare Administrative Contractors to determine how they ensure that the home health documents met the face-to-face encounter requirement.  Finally they reviewed guidance and documents and policies from CMS or the HH MACs about monitoring the face-to-face requirement.

Guess what they found? 32 percent of home health claims that required face-to-face encounters, the documentation did not meet Medicare requirements, resulting in $2 billion in payments that should not have been made. Furthermore, physicians inconsistently completed the narrative portion of the face-to-face documentation. Some face-to-face documents provide information that, although not required by Medicare, could be useful, such as a printed name for the physician and a list of the home health services needed. CMS oversight of the face-to-face requirement is minimal.

 They recommend that CMS

 (1) Consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation, (2) Develop a specific strategy to communicate directly with physicians about the face-to-face requirement, and (3) Develop other oversight mechanisms for the face-to-face requirement.

How did CMS regard the study?  They concurred with all of the OIG recommendations.

Actually having a standard form and educating the physicians - Who would have thought!

(Sarcasm font needed for the next sentence.)

No let's not think and allege overpayments to home health agencies!

For more information please use the following link.

http://oig.hhs.gov/oei/reports/OEI-01-12-00390.pdf