Face-to-Face Encounter Requirements Delayed.
CMS has issued an update to the implementation of the physician face-to-face encounters by delaying enforcement of the new requirements until April 1, 2011. There have been continuing questions regarding what the home care community should be doing during this enforcement suspension period.
Use the internet and other resources to find the answers to your questions
Develop internal policies and procedures around the requirement
- What policy covers the verification of encounter?
- What policy covers the verification of encounter documentation from a hospitalist referral?
- How do you handle patients who cannot leave home (bedbound)?
- How is staff education on the requirement being handled?
Notify physician and referral sources of the requirement
- Create letters and documentation to help educate the physicians, patients and referral sources.
Check with your software vendor on product changes
- Does your software track the encounter document?
- Does your software alert you to encounter documents missing before billing?
- Make sure you fully understand how your software will help you in this requirement and create processes and procedures for any gaps.
The industry will continue to receive more clarifications from CMS regarding the Face-to-Face encounters over the next few months. Be prepared to review and make changes to your policies and procedures as these come out.
It is important to note the face-to-face encounter requirements are still implemented as of January 1, 2011; however, non-compliance will not result in a payment denial during this suspension. This allows providers and physicians to work out their processes to comply fully with the rules by April 1, 2011; there will be NO additional delay, so iron out the processes now. Providers can admit patients during the suspension period without a documented face-to-face encounter, but providers should be making efforts to comply as quickly as possible.