CMS hosted a Special Open Door Forum call yesterday to provide an opportunity for physicians/practitioners, home health agencies and/or all other interested parties to provide feedback on both a paper clinical template and an electronic clinical template for face to face documentation.
Many questions were raised and often the presenters were unable to answer the audience’s questions; the presenters stated they would provide answers during at the April call. The PowerPoint presentation (see slide 5) raised many more questions on which physicians could actually certify homecare; the hospitalist or the community physician. Again the presenters were unable to clarify the regulation for the audience. The presenters were actually debating among themselves whether a discharge planner or physician’s staff could assist completing the documentation for the face to face. A caller confirmed that this was acceptable and CMS had already addressed this issue in the CMS Face to Face Questions, question number 8.
CMS is seeking public comment on this voluntary paper clinical template. Feedback and questions can be sent to: HomeHealthTemplate@cms.hhs.gov.
Additional Special Open Door Forum calls on the templates will be held on April 8 and May 6, 2015, both at 1:00 PM Eastern Time.
In the Alliance’s continued advocacy on the Physician Face-to-Face Requirement, agencies that have ongoing appeals of claims denied for “invalid” F2F documentation are encouraged to send the number of denials, amount of money tied up in those claims, and the status of the appeals to James Fuccione at HCA.
We will share these data by congressional district with the Massachusetts federal delegation so that they can follow up with CMS. Months after a letter was sent from US Senators from the New England region on the same subject, CMS has failed to respond and the Alliance wants to make sure this issue gets the attention it deserves.
Please send this information, along with any questions, to James Fuccione at the Alliance.
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