Face to Face (F2F)
Documentation Changes for
Physicians
Situation
• On August 3, 2016, Illinois began participation
in a CMS Home Health Pre-Claim Review
demonstration project. After 30 days in the
demonstration project, Advocate at Home
found that:
1. More than 25% of admissions did not meet the
CMS documentation requirements – we were
unable to obtain necessary documentation, even
30 days post referral.
2. Completing a separate Face to Face form, even
the CMS form, is no longer acceptable.
Background
CMS is Looking for Ways to Reduce Fraud
1. Illinois and other demonstration states were
chosen due to their high rate of Home Heath
fraud.
2. While burdensome for everyone, Advocate at
Home has always collected documentation
necessary to support Medical Necessity. We
have done so to provide the right patient care
and to protect Advocate and our physicians
from allegations of fraud.
Assessment
1. Advocate at Home, because of its size,
presents a large ROI opportunity for the OIG
and is at greater risk of an OIG audit. We
expect one.
2. Delays in receiving CMS required
documentation at the time of referral:
a. Affect patient safety and effective hand offs to Home Health
b. Prevent Advocate at Home, and other Home Health agencies,
from being able to bill for service provided to patients. Based on
our initial experience, we will potentially face millions of dollars
in write offs if today’s processes do not change.
c. Have already caused area Home Health agencies to close.
New Requirements
Beginning Monday Oct 3, 2016 Advocate at Home:
1. Will require Face to Face (F2F) encounter elements be
documented in the physician progress note. Separate F2F
forms will not be accepted.
2. Will require the following documentation at the time of
referral.
a. A physician order
b. A physician progress note written by a Physician, Resident, APN or
PA documenting all of the required F2F encounter elements (at
Bromenn/Eureka APN and PA notes must be cosigned by a physician)
c.
Physician certification statement signed by the physician
i.
Name of community physician if certifying physician is not following the
patient
Checklist for Home
Health Referrals –
Physician
Documentation
Beginning Monday, October 3rd, 2016
Advocate at Home:
1. Will require Face to Face (F2F) encounter
elements be documented in the Physician,
Resident, APN or PA progress note. Separate
F2F forms will not be accepted.
2. Will require the following documentation at
the time of referral.
a.
b.
c.
A physician order
A progress note written by a Physician, Resident, APN or PA
documenting all of the required F2F encounter elements
Physician Certification Statement signed by the physician
Physician Progress Notes
Required Elements
i.
ii.
iii.
iv.
v.
Date of visit (within 90 day prior/30 days after Home
Health start of care date)
Documentation that patient was treated during the
encounter for the primary reason for Home Health
services
Narrative documentation – why patient requires skilled
home health
Narrative documentation – why patient is homebound – 2
reasons
v. Physician, Resident, APN or PA signature, credentials
and date
Physician Certification Statement
Required Elements
c.
Physician certification statement signed by the physician
i.
“I certify/recertify that this patient is confined to his/her home (and meets homebound
criteria) and needs intermittent skilled nursing care, physical therapy and/or speech
therapy or continues to need occupational therapy. The patient is under my care, and a
plan of care has been initiated and will periodically be reviewed by a physician. I (or an
acute/post acute physician or collaborating NPP) had a Face-to-Face encounter with this
patient on the above date, during which the primary reason for home health services was
addressed. I have a clinical note (supporting documentation) documenting my encounter
with the patient in the patient’s medical record to support certification and eligibility for
home care, and will make it available to Advocate Home Health Services upon request.”
ii.
“I am the certifying physician and will follow the patient in the community.”
or
iii.
iv.
v.
vi.
“I am the certifying physician, but Dr. (Name and Credentials) will follow the
patient in the community.”
Certifying Physician Signature/Credentials
Certification Date
Physician Printed Name
Options for Documenting
1. Use MeditechTemplate:
1. Complete a Physician Progress Note using the Face to Face Encounter
template
2. Complete the Physician Certification Statement within the Face to Face
Encounter template
2. Use Meditech & enter your own Physician Progress Note
a. Document the required F2F elements in your Physician Progress Note
b. Physician Certification Statement can be included in the Physician
Progress Note
i.
Or a paper Physician Cert Statement can be used with the electronic note
3. Use another EMR/Medical Record
a. Document the required F2F elements in a Physician Progress Note
b. Physician Certification Statement can be included in the Physician
Progress Note
i.
Or a paper Physician Certification Statement can be used with the electronic note
c. At the time of referral, include a copy of the Physician Progress Note,
and if not embedded in the note, a copy of the Physician Certification
Statement
Using CareConnection
for Documentation
Entering the
CareConnection Order
for Home Health
Step 1 – It starts with the order
• F2F documentation is triggered from the
Discharge Planning Eval Adult order when
Home Care Evaluation is selected as the reason
for Discharge Eval:
Step 2 – F2F Documentation Alert
• An alert will appear indicating patient has an
active order for HH and F2F documentation is
needed; click on links to go to documentation
Documenting using
PowerNote
Step 3 - Accessing PowerNotes
2. Choose the
Miscellaneous Catalog
Dropdown to select
Home Health Face to
Face
1. To access the notes
Click on the Catalog tab
within PowerNote
3. If ordering both
Home Health and Home Oxygen,
you must complete a PowerNote
for both.
Step 4 - Placing Note Correct Folder
• Under Type, Right Click to have the pop up box
appear.
• Check the All Note Type list to be able to scroll and
find the Home Health Certification Folder.
• Save the powernote as a precompleted favorite –
the folder type will stick for the note if this is done.
Step 5 – F2F PowerNote
1. Choose Date
and Time from
Calendar
2. Complete Clinical
Reason/Diagnosis for Home
Health i.e. Diabetes, Wound Care
3. Select One or
More of the
Homebound
Reasons
4. Choose One
or More of the
Home Care
Interventions
5. Identify outpatient physician
managing patient
F2F Documentation Location
• Completed F2F form will appear in the Physician
Documentation folder > Home Health
Certification
PowerNote is Complete!
• When Certification field is clicked, documentation is
added to Physician’s Progress Note in Patient’s Care
Connection Record
Documenting the
Certification Statement
Step 1 – F2F Documentation Alert
• An alert will appear indicating patient has an
active order for HH and F2F documentation is
needed; click on links to go to documentation
Step 2 - F2F Certification Statement
1. Enter the
date the F2F
Assessment was
completed
3. If you are not the physician
following the patient postdischarge please enter in the
physician who will follow the
patient in the community
2. Click “Yes” if you
are physician
following patient
post-discharge or
“No” if you are not
Step 3 - Accessing Reference Text
• Right click on box to left and select Reference
Text for detailed examples of how to fill in the
form
Step 4 – Resource Guide
Reference text is a
resource guide of
how to complete the
F2F documentation
Summarizes
home bound
criteria examples
(2 must be met)
Provides
examples of
eligibility
criteria
Questions?