Letter to Dr. Donald Berwick, Head of the Centers for Medicare and Medicaid Services - Courtney Urges Simple Changes to Streamline Face-to-Face Reporting Requirement for Home Health Care Services

Letter

Dear Dr. Berwick,

We continue to hear concerns about new face-to-face reporting requirements for home health care services that took effect on April 1, 2011. We fear these concerns will become reality over the coming weeks and months and will manifest in inadvertent provider violations and interrupted access to necessary home health care services. And, while we appreciate CMS's decision to delay implementation and ramp up education over the past three months, we believe that changes should be made to the face-to-face reporting requirements in order to avert consequences for patients and providers.

As you know, the final face-to-face reporting rule requires that a physician document a patient narrative on the face-to-face encounter including metrics such as the patient's medical condition, clinical findings, reason for being homebound, and services needed. Considering physicians are already required to document a patient's need for home health services in form 485, the "Physician Certification and Plan of Treatment," requiring separate documentation of the face-to-face encounter is duplicative. Adding a line to form 485 that certifies the face-to-face encounter would go a long way with addressing confusion and eliminating redundancies for physicians. Further, this change falls completely within the purview of the law, which does not specify the documentation vehicle for the face-to-face encounter.

The patient narrative on the face-to-face encounter is also required to be documented directly by the certifying physician, even if an advanced nurse practitioner, physician assistant or other non-physician practitioners performs the face-to-face encounter. Contrastingly, CMS allows non-physician providers and support staff to transcribe clinical information for the physician to certify. Allowing documentation of the face-to-face encounter by non-physician providers so long as the physician certifies the clinical findings and the patient's need for home health care services will also go a long way with eliminating cumbersome reporting requirements.

We share your commitment to preserving access to necessary care for Medicare beneficiaries and we believe that modifying the face-to-face reporting requirements is necessary for upholding this objective. Thank you for your attention to this matter and please do not hesitate to contact us or our staff at any time.

Sincerely,

Joe Courtney

Source