The Centers for Medicare and Medicaid Services (CMS) recently issued a special edition of their MLN Matters newsletter in an effort to clarify the new documentation requirements for the face-to-face (F2F) encounter requirement. The article reiterates that the encounter document must include an explanation of why the clinical findings support that the patient is homebound and in need of either intermittent skilled nursing services or therapy services. Diagnoses alone do not support the need for skilled service and standard language such as “taxing effort” or a notation such as “gait abnormality” alone do not support homebound status.
CMS reviews the coverage criteria for skilled nursing and therapy home health services and describes the two criteria required for a beneficiary to be homebound. Examples of appropriate documentation are provided relative to the coverage criteria.
Several attachments are also included that show acceptable and unacceptable examples of F2F encounter documentation using various F2F document formats. The difference in the acceptable and unacceptable examples is stark. CMS provides an unacceptable example of a F2F encounter documentation using prohibited criteria such a diagnosis alone to support skilled services while using a detailed clinical summary on a physician visit note as an acceptable example.
It would have been helpful if CMS also provided an example of an acceptable F2F encounter using a stand alone form where single statements are often used to explain the need for skilled services and the reason for homebound. Although, we do not believe CMS intends to require a narrative similar to what is in the acceptable examples, the concept remains without change, there needs to be an explanation of why the clinical findings support that the patient is homebound and in need of skilled nursing or therapy services.
CMS has provided the article to Part B contractors as well for distribution to physicians and agencies should use the tool to further educate physicians.
To view the MLN Article click here.