Agencies could run into issues with F2F encounters under Medicare's new 30-day billing cycle
With the launch of Medicare's new payment model less than six months away, home care providers are feeling trepidation about the impact of shorter billing cycles on some key aspects of agency compliance.
Specifically, providers are questioning how shorter billing cycles will work with current regulations which allow the crucial face-to-face encounter between patient and physician to take place after the patient has been admitted to home health.
Under current Medicare regulations, the F2F encounter can take place up to 30 days following Start of Care -- but Home Health Solutions Director of Special Projects and Appeals Heather Calhoun warns that waiting too long could jeopardize a home health agency's ability to meet deadlines for new 30-day billing cycles under the Patient-Driven Groupings Model (PDGM). "The way it works now, the home health agency admits the patient, completes the OASIS, and if the face-to-face encounter related to the primary reason for home health care hasn't been done, it's not a big deal because you still have 30 days," Heather told attendees of a recent free webinar presented by Home Health Solutions. "You just call the doctor and get the visit scheduled in the next few weeks." It's the next step, when the agency creates a plan of care for the patient and gets it signed by the physician, that could make things difficult under PDGM, Heather said. "The agency creates the plan of care and sends it to the certifying physician to sign -- but wait a minute! The certifying physician cannot sign that plan of care until the F2F encounter has actually taken place, because the physician is certifying that an actual F2F has already taken place," Heather said. "If the certifying physician does sign the plan of care without the documentation showing the F2F has occurred -- and documentation includes the actual clinical note from the encounter -- you can expect a denial." PDGM's 30-day billing cycle will force home health agencies to expedite a face-to-face physician visit for homebound patients in order to get the plan of care signed in time to meet new deadlines, Heather said.
"When you only have 30 days to get that claim submitted, you'd better get fast," Heather said during "Looking at the Face-to-Face with a Critical Eye," a free webinar presented by Home Health Solutions. "Technically, you will still have 30 days to get the F2F done, but you can't actually wait that long under PDGM." One of the most important areas of concentration for home care providers preparing for PDGM should be working with physicians to stress the urgency of new turnaround times, Heather said. "Your clinicians needs to understand that the appointment needs to be made faster than in the past. Then you’d better talk to your doctors to let them know that turnaround times are about to get tighter, that they're going to need to see homebound patients faster," Heather said. "Everything is going to need to take place much faster," she said. "You're going to need to get that physician's clinical encounter note, make sure that the certifying physician accepts it as a valid F2F encounter and includes it into the medical record, and then get the plan of care signed pronto! "
Home care providers need to begin preparing physicians for expedited timetables now, Heather said. Our brochure can help Don't know what to say to physicians about upcoming changes under PDGM? We know how hard it is to have those conversations -- and that you need to keep it brief and easy-to-understand for busy physicians who, frankly, may not be as interested in your new timetables as you'd like them to be.
We've put together a helpful brochure in a "Tools for Tough Talk" package available in our online store.
The brochure template is designed to be customized with your agency name and contact information, printed out, and shared with your referral sources.
It offers a quick, informational look at the new timeframes ahead under PDGM in an easy-to-read format designed to get important information to busy physicians. We've added a one-page look at primary diagnoses which will no longer be allowed under the new payment model. Check it out in the Solutions Shop, where it's just $19.99.