Review Choice affirmation rates may hinge on documentation
The best defense for home health agencies awaiting the launch of Medicare’s new Review Choice demonstration may be a solid understanding of effective documentation practices to pass reviewer scrutiny, according to J’non Griffin owner and president of Home Health Solutions.
“Effective documentation is one of three primary components necessary for a successful affirmation rate under Review Choice, “ J’non said. “Agencies are also going to need an expedited claims process, with a mechanism in place to clearly identify responsibilities and timeframes so that the pertinent information can be gathered.
"The third component is to review all necessary information for errors, omissions and discrepancies before submission. The review can be done by either a knowledgeable in-house reviewer or by a reputable firm providing outsourced service – but either way, agencies are going to need someone making sure all the proper pieces are in place.”
(To read about helpful services from Home Health Solutions, click here.)
Although the specific launch date for Review Choice has yet to be announced, the Centers for Medicare and Medicaid Services (CMS) is expected to make the announcement at any time, following final approval issued by the federal Office of Management and Budget earlier this month.
Florida, Texas, Ohio and North Carolina are set to go next in the rollout of the Review Choice demonstration, although no specific order has been announced and no dates have been provided for those states.
“It’s important for agencies in all five of the targeted states to take a hard look at their documentation practices to identify weaknesses and make improvements as needed,” J’non said.
During the pre-claim review demonstration in Illinois in 2016-17, non-affirmation rates were attributed in large measure to documentation errors agencies made with the face-to-face encounter between patient and physician, failing to establish medical necessity for services rendered, and violations of homebound eligibility requirements.
F2F compliance is crucial
Two years after the last claim review demonstration, statistics from the CMS review strategy known as Targeted Probe and Educate (TPE) indicate that agencies are still struggling with correctly documenting the F2F. Errors in F2F documentation consistently rank among the top reasons for claim denials.
How well versed in face-to-face encounter documentation is your agency? Can you answer these questions?
Q. What happens when the certifying physician who established and signed the Plan of Care is not the physician who will follow the patient through the episode of home health care?
A. Medicare allows a physician who attended to the patient in an acute or post-acute setting, but does not follow the patient in the community, to certify the need for home health care based on their contact with the patient, and establish and sign the Plan of Care. The acute/post-acute physician would then “hand off” the patient’s care to his or her community-based physician. CMS wants to know who will be following the patient if it is not the certifying physician. The community physician must be identified even though he/she did not certify the Plan of Care. This may be noted in the record in the form of a verbal order from the M.D. who signed the Plan of Care and a verbal order from the community M.D. who will take over.
Q. What extra steps should a home health provider take when the face-to-face encounter is conducted by a nurse practitioner or clinical specialist rather than the certifying physician?
A. Medicare allows several different types of providers to conduct the face-to-face encounter. In addition to the certifying physician, the F2F may be conducted by a different physician who treated the patient at an acute or post-acute facility from which the patient was directly discharged to home health, a physician assistant, a nurse practitioner, a clinical specialist or a midwife. Provider types other than physicians must meet the definition for the position as specified under the Social Security Act and must be working in collaboration with a physician according to State law. It is up to the home health provider to confirm that the physician assistant, nurse practitioner, clinical specialist or midwife is working in collaboration with the physician, and that this relationship is documented in the medical record.
These are two of the helpful tips covered in “The Dirty Dozen: 12 Commo F2F Mistake,” a 10-page digital guide from Home Health Solutions. Knowing the answers to these and other questions may be more important than ever for home health providers bracing for the Review Choice launch.
F2F Guide: $24.99
“F2F: The Dirty Dozen” is a 10-page digital guide which highlights 12 of the most common documentation errors that can invalidate the F2F encounter. We cover the basics needed for F2F compliance, provide a helpful F2FDo and Don’t List, and even include a brief section on handling ADRs in the case of missed signature, dates, etc. Available as an instant download. No shipping costs or waiting. Check it out in The Solutions Shop, our online store.