Does the certifying physician need to co-sign the F2F when a different provider performs it?
Home care providers are looking hard at new guidance Medicare administrative contractor Palmetto GBA added to its web site last week for its implications regarding documentation of the face-to-face encounter between patient and physician. Is Palmetto recommending that a physician who certifies a home health patient co-sign a face-to-face encounter when it is performed by someone else? The question arose when the following sentence was included in guidance posted here. For how to handle Additional Documentation Requests known as ADRs.
The specific wording which snagged attention is: “If the face-to-face was performed by someone other than the certifying physician, the date of the encounter must be recorded and signed by the certifying physician or the encounter needs to be co-signed by the certifying physician.” Home Health Solutions Director of Special Projects and Appeals Heather Calhoun has presented several popular educational webinars on face-to-face documentation, and has advised attendees that extra documentation is always required when the certifying physician is not the one who performed the face-to-face. “The certifying physician does not have to be the one who performs the face-to-face,” Heather says. “While no one but a physician can refer a patient to home health, Medicare does allow other physicians as well as other provider types to complete the F2F. “But in those cases, the certifying physician always has to acknowledge that he or she accepts the F2F encounter by the other provider as valid for certification – and enter it into the medical record,” Heather said. Palmetto seems to be saying the same thing when it advises the certifying physician to record the date of the F2F encounter and sign -- or co-sign the F2F. One of the “Dirty Dozen” Failure to “connect the dots” between the certifying physician and a different provider who performed the F2F is identified as one of the most commonF2F documentation errors in “The Dirty Dozen,” a guide to 12 common F2F errors published by Home Health Solutions. “Sometimes the physician who conducted the F2F encounter is not the same as the physician who certifies the Plan of Care,” the Guide states. “If this is the case, documentation must connect these two physicians. Documentation must show that the certifying physician acknowledges that a valid F2F encounter occurred — specifically that he or she accepts the encounter with the other physician as the F2F encounter and that the encounter has been incorporated into the certifying physician’s own medical records.” “The Dirty Dozen” is on sale now for $19.99 in The Solutions Shop, the online store on the Home Health Solutions web site. That price includes a link to view our most popular 60-minute webinar on F2F documentation. Other provider types It isn’t always another physician who conducts the F2F. Medicare allows some specific non-physician provider types to perform the F2F as well. Those 5 specific providers allowed to perform the F2F are: • The certifying physician (the M.D. signing the Plan of Care )
• A different physician who cared for the patient in an acute or post-acute care facility (from which the patient was directly admitted to home health)
• A nurse practitioner or clinical nurse specialist (defined in section 1861(aa)(5) of the Social Security Act) who is working in collaboration with the physician in accordance with state law
• A certified nurse-midwife (defined in section 1861(gg) of the Social Security Act) and authorized by state law
• A physician assistant (defined in section 1861(aa)(5) of the Social Security Act) acting under the supervision of the physician “Documentation should always make very clear the association between the physician and the other non-physician provider type who performed the F2F,” Heather said. "Does the nurse practitioner work for the certifying physician? Make sure documentation says so." Dates and signatures Palmetto’s guidance specifically mentioned that the certifying physician should record the date of F2F encounter when it was performed by someone else. Getting the dates and signatures right is always crucial part of F2F documentation compliance, Heather said, and another area in which errors often occur. A valid F2F will include: _Date the F2F occurred _Name of the person who performed it _That person’s signature _Date that person signed the F2F When the person who performed the F2F is not the certifying physician, these additional dates and signatures will be needed: _Signature of physician accepting the F2F as valid – either on the F2F or on an attestation added to the medical record. If using an attestation, make certain it references the date the F2F occurred, and the name of the person who performed it. _Date the certifying physician signs to accept the F2F as valid Interested in more F2F guidance? The Solutions Shop, the online store on the Home Health Solutions web site, can help you shore up your F2F accuracy with several products now on sale.
Our RCD Staff Training Workbook devotes a full section to the F2f – with review questions and Q&As on the F2F from home health agencies -- and it’s on sale now for $49.99 through March 2 as part of our RCD Readiness Sale. This workbook offers four sections of material for four easy staff training/review sessions to shore up on documentation requirements for skilled need, homebound status, certification and the F2F. It's a great resource for Review Choice Demonstration prep -- but we recommend you keep it on hand to use for all new hire orientation sessions, too. You'll only need to order one workbook for your agency; you will be able to email copies to all staff members.