About the Face-to-Face Encounter Requirement

The new Home Health Face-to-Face Encounter provisions of the CMS-1510-F Final Rule states that the physician must document that the physician or a permitted nonphysician practitioner (NPP) has had a face-to-face encounter with the patient.  One of the main reasons for this is that the encounter will enable the certifying physician to more accurately certify the “homebound” and “in need of skilled services” eligibility requirements.  This face-to-face encounter is required to have occurred in the 90 days prior to admission, or in the 30 days immediately after admission.  The statutory language in the Affordable Care Act requires that prior to certifying (which means prior to signing the 485), the physician must document that the face-to-face encounter occurred.  The law requires this as a condition for HH payment. The documentation of the encounter must be a separate and distinct section of, or an addendum to, the certification, and the documentation must include why the clinical findings of the encounter support HH eligibility.

The agencies are held responsible for the certifying physician's encounter documentation, which means that the agency has a signed and dated statement from the physician stating that an appropriate face-to-face encounter has occurred, however CMS is not holding the HHA responsible for the physician’s own medical record documentation associated with the encounter.

Hospice has a similar but slightly different requirement.  A hospice physician or advanced practice nurse must visit the patient to determine continued eligibility prior to the 180-day recertification and each subsequent recertification, and attest that such visits took place no more than 15 calendar days prior to each recertification.

Setting up Barnestorm for the Face-to-Face Encounter Requirement

We have determined that for the purposes of tracking this requirement, the easiest method is to use a verbal order as the cover page / attachment, since most physicians will be familiar with that format.  In order to keep this as simple as possible, we have added 2 new order types:  Face-to-face HH and Face-to-face Hospice, which will automatically pull your text into the order.

Have one person from your agency follow these instructions to set up the [T] Text Items. 

One is for Home Health, and one is for Hospice, so only create the ones your agency needs.

 Part 1 - Set up Text Items

1. Go to Codes > POC Codes > [T]Text Items.
2. Click the New button.  Make a note of the 4-digit code that is assigned. 
3. Now copy and paste the appropriate text from below into the Text area.
4. Click the Save button.
5. If you provide both Home Health and Hospice services, repeat this process for the other text item.

Part 2 - Set up Orders

1. From the main menu, go to Codes > Security > Global Settings > Orders.
2. Fill in the 4-digit code for Verbal Orders TBox Code for Face-to-face HH Encounter and/or Verbal Orders TBox Code for Face-to-face Hospice Encounter.

Here is the Home Health text:

VERIFICATION OF A FACE-TO-FACE ENCOUNTER

Per the Affordable Care Act, documentation of a face-to-face encounter with the patient during the 90 days prior to home health admission, or the thirty days immediately after home health admission, is required. 

Please complete the following sections:

Date of the Face-to-face Encounter: ____/____/____ 

The face-to-face encounter was performed by

[ ] me    [ ] another person under my supervision _________________________________

Findings that support that the patient is homebound:

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________

Findings that support the need for intermittent skilled nursing or therapy (physical/occupational/speech):

_________________________________________________________________________________

_________________________________________________________________________________

And here is the Hospice text:

VERIFICATION OF A FACE-TO-FACE ENCOUNTER

Per the Affordable Care Act, a hospice physician or advanced practice nurse must visit the patient to determine continued eligibility prior to the 180-day recertification and each subsequent recertification.  Documentation that this encounter occurred during the 15 days prior to the recertification is required.

Please complete the following sections:

[  ]  The face-to-face encounter was performed by me on ____/____/____

       OR

[  ]  The clinical findings of my encounter on ____/____/____ have been provided to the certifying physician for use in determining continued eligibility for hospice care.

Signed ________________________________________________     ____/____/____ 

Findings that support that the patient has a life expectancy of six (6) months or less if the terminal illness runs its normal course:

_________________________________________________________________________________

_________________________________________________________________________________

_________________________________________________________________________________