Earlier this month, CMS held a Special Open Door Forum for the voluntary electronic and paper clinical template for the home health Face-to-Face (F2F) encounter document. During this call, a presenter provided inaccurate information regarding what would be acceptable documentation within the physician’s medical record to support home health eligibility.
Several participants questioned the presenters about the CMS policy that allows a physician to sign information from an agency’s assessment and incorporate it into his or her medical record to support eligibility. CMS answered by comparing agency documentation to consultation notes that may be found in a physician’s record, saying that CMS does not actually consider these documents to be a part of the physician’s record, since they are not generated by that physician. CMS indicated it would only look for documentation the physician generated to support home health eligibility. However, this interpretation goes against what CMS has spelled out in the final rule for home health prospective payment system (HHPPS) rate update.
NAHC contacted CMS requesting clarification of this matter. On March 24, CMS released the following statement:
“In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services. Per 42CFR 424.22 (a) and (c), the patient’s medical record must support the certification of eligibility and documentation in the patient’s medical record shall be used as a basis for certification of home health eligibility. Therefore, reviewers will consider HHA documentation if it is incorporated into the patient’s medical record and signed off by the certifying physician. More guidance will follow regarding the review of home health claims shortly. CMS apologizes for the confusion.”
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