Home Health & Hospice Week

PPS rule commenters bash physician narrative.

Medicare officials may not have mentioned the face-to-face requirement in the 2014 PPS proposed rule, but that didn’t stop providers and industry reps from tackling the hot button subject head on in their comment letters.

The principle of requiring a physician en-counter for initial home care episodes is not a bad one, multiple commenters allowed. "Home health agencies … think that a F2F encounter is important for the patient," said Barbara McCann with In-terim Healthcare in the franchise company’s letter commenting on the home health prospective payment system proposed rule for 2014. "We’re perfectly fine with the law," said McCann. "It is the regulations [the Centers for Medicare & Medicaid Services] built around the law that are onerous, damaging and expensive."

F2F has "created additional work for the doctors," noted Doug Beckwith with Big Bend Home Health in Alpine, Texas in the agency’s comment letter. As a result, "Face to Face has curbed referrals, which is bad for patient care and more costly to Medicare in the long run."

"Many physicians who interact with our members have expressed confusion or have complained to New York HHAs about" F2F, reported the Home Care Association of New York State in its comment letter. "Some physicians have said that they will refuse to provide the required documentation."

"The F2F requirement is a bigger burden on them than you estimated," McCann says of referring physicians.

Physicians find F2F documentation duplicative of their other home health documentation requirements, multiple commenters complained. "I don’t blame the physicians for being irritated by agencies who are trying to meet the regulatory requirement and also get paid," said McCann, representing Interim’s 300-plus independently owned franchises in 43 states.

HHAs must spend precious time and resources educating referring physicians on the rule. "The process by necessity requires the agency to educate physicians in addition to the agency’s own staff," McCann related. "The training offered by CMS did not come close to clearly defining the role of the physician and the expectation for the content of the F2F document."

Even when docs submit F2F documentation, it often isn’t up to the regulatory standards. HHAs must spend time and effort sending it back for correction, much to the physician’s annoyance.

"Then when you think you have everything correct, you get a RAC audit who says that the F2F does not meet the requirement because of something as silly as a word is out of place or missing," Beck-with fumed. The regulation creates "a nightmare of problems and additional expense for the agencies that are trying to comply with this regulation."

"Agencies are now … experiencing more denials than ever due to F2F," McCann agreed. "The reason for most of the denials? Physicians are not completing the F2F documents with enough narrative information."

HHAs On The Hook For Docs’ Paperwork

Physicians often simply give up, because they have no skin in the game financially, commenters maintained.

"Home health agencies’ claims are being denied because physicians, not the agencies, are failing to meet the requirements," McCann stressed.

"What other segment of healthcare overseen by CMS … has a provision like this where they have no control over the compliance with this provision?" asked financial consultant John Reisinger with In-novative Financial Solutions for Home Health in Tampa, Fla.

"The HHA that receives the referral from the doctor has no power over the doctor to force him/her to comply with all the facets of the F2F provision," Reisinger said in his comment letter. "Yet the HHA (not the doctor) faces all the regulatory and financial ramifications."

Also: Some patients can’t even get to a physician for a visit because they are homebound, protested HCANYS. That’s especially true in rural areas with long travel distances to the doctor’s office and a dearth of transportation options. The end result is limited access to home care.

Note: The proposed rule is at www.gpo.gov/fdsys/pkg/FR-2013-07-03/pdf/2013-15766.pdf. To read the 96 comment letters submitted, go to www. regulations.gov/#!docketDetail;D=CMS-2013-0140 and scroll down to the "Comments" section.