In its February 2018 newsletter CGS Medicare reports that many physician certifications do not contain a statement documenting the date of the face-to-face for home health encounter. Most providers utilize the CMS485 form for the plan of care and physician certification. Does your certification statement meet the current requirements? The home health certifying physician must certify (attest) that:
- The home health services are or were needed because the patient is or was confined to the home (https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/ Downloads/bp102c07.pdf);
- The patient needs or needed skilled nursing services on an intermittent basis (other than solely venipuncture for the purposes of obtaining a blood sample), or physical therapy, or speech-language pathology services. Where a patient’s sole skilled service need is for skilled oversight of unskilled services (management and evaluation of the care plan as defined in Medicare Benefit Policy Manual, Pub. 10002, Ch. 7, §220.127.116.11 (https://www.cms.gov/Regulations-and-Guidance/Guidance/ Manuals/Downloads/bp102c07.pdf)), the physician must include a brief narrative describing the clinical justification of this need as part of the certification, or as a signed addendum to the certification;
- A plan of care has been established and is periodically reviewed by a physician;
- The services are or were furnished while the patient is or was under the care of a physician; For episodes with starts of care beginning January 1, 2011, and later, in accordance with §18.104.22.168 below, a face-to-face encounter occurred no more than 90 days prior to or within 30 days after the start of the home health care, was related to the primary reason the patient requires home health services, and was performed by an allowed provider type. The certifying physician must also document the date of the encounter.
Having trouble getting physicians to complete face to face for home health?
1. Make sure the CMS485 includes the following statement in Form Locator 26:
I certify that this patient is confined to his/her home 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 I have authorized services on this plan of care and will periodically review the plan. The patient had a face-to-face encounter with an allowed provider type on (date) and the encounter was related to the primary reason for home health care. Physician’s Signature and Date Signed: John Doe, MD 11/05/2016
Physician’s Name and Address: John Doe, MD
2121 Washington Pkwy Suite 220
Washington, DC 20000
Note: This represents one example of a valid certification statement. Certification statements can be included in varying forms or formats as long as the content requirements (#1-5 above) for the certification are met. If the agency’s current physician certification statement does not document the date of the face-to-face encounter, a statement as the example above can be added to another locator on the plan of care.
2. Efix a 'Sign-Here' Sticky on the CMS 485 to remind the Physician of where and what to sign.
Mark the sticky to ask for the the most recent face to face encounter date.
3. Use the physician office visits as a marketing opportunity.
Provide printable progress reports on your patients during the office visit. Share new information regarding staff training and careplanning.
4. Include a Careplan Oversight Documentation Form for physicians to record time spent monitoring the home health careplan.
5. Offer to track careplan oversight (CPO) so the physician can bill Medicare for Physician Careplan Oversight.
This is a VERY effective Physician Marketing Strategy!.
6. Use your EMR's Physician Portal for order-signing.
Most EMRs have physician portals. Make sure the Portal prompts the physician to include the date of the face-to-face encounter.