Home Health Requirements Reform From Senators
57 Senators Urge CMS To Reduce Paperwork Burden For Face-To-Face Home Health Requirement.
HEALTHCAREfirst, Inc., provider of leading-edge home health care and hospice technologies, has been monitoring the flood of news recently with reports of Senators attempting to reduce the amount of paperwork involving the face-to-face home health requirement. Following is an article from InsideHealthPolicy.com discussing the upcoming challenges health care reform faces.
Posted: May 18, 2011
A group of 57 senators is urging CMS to reduce the paperwork involved in certifying face-to-face encounters for home health services, and a small bipartisan group of House lawmakers just started drumming up support for a similar dear-colleague letter to CMS.
In December, CMS delayed the face-to-face reporting requirement for home health providers that was established by the health reform law. CMS later issued a final rule on documentation for the in-person meetings, and the requirement took effect on April 1. Since then, Congress has received an earful from patient advocates and provider groups about the documentation requirements, which they predict will interrupt patient care and cause physicians to inadvertently violate the requirements.
The final face-to-face reporting rule requires physicians to document patient narratives of face-to-face encounters, including metrics such as the patient’s medical condition, clinical findings, reason for being homebound, and services needed.
The senators are asking CMS to eliminate the narrative requirement and accept physicians’ certification that patients need home health services. Or CMS could add a line to the current physician documentation requirements in the “Physician Certification and Plan of Treatment,” certifying a face-to-face encounter. (The second option is the approach requested in the House dear-colleague letter, which has been signed by Reps. Joe Courtney (D-CT), Walter Jones (R-NC), John Lewis (D-GA) and Linda Sánchez (D-CA).
The certifying physician must document that patient narrative under the final rule, even if an advanced nurse practitioner, physician assistant or other non-physician practitioner performs the face-to-face encounter. Conversely, CMS lets non-physicians and support-staff transcribe clinical information for the physician to certify. Thus, the Senate and House lawmakers want CMS to let non-physician practitioners fill out the forms for face-to-face encounters, provided that physicians sign the forms.
“Specifically, we are concerned about the documentation requirements in the rule placed upon ordering physicians, which are burdensome, duplicative, and impractical for many doctors, especially those in rural and underserved areas,” according to a letter signed by 50 senators that was spearheaded by Sens. Maria Cantwell (D-WA) and Susan Collins (R-ME).
Sens. John Kerry (D-MA), Tom Coburn (R-OK), John Cornyn (R-TX), John Barraso (R-WY), John Thune (R-SD), Pat Roberts (R-KS), Mike Johanns (R-ME), and Richard Durbin (D-IL) each sent separate letters that make similar requests, a home health lobbyist says.
The National Association for Home Care and Hospice (NAHC) is handling the face-to-face requirement for hospice care separately. The changes needed for home care are more urgent and can be handled administratively. On the hospice side, NAHC seeks changes to the law. To that end, Sens. Ron Wyden (D-OR) and Pat Roberts (R-KS) recently introduced a bill that would require CMS to test pay cuts for Medicare hospice services for two years in a pilot before those reductions were allowed to take effect permanently. The legislation would ease the face-to-face requirement by allowing nurse practitioners, physician assistants and others to conduct those face-to-face interviews. It would require hospice accreditation every three years, compared with the existing eight-year accreditation cycle.
Source: Inside Health Policy.