HHA Referrals: More documentation requirements weigh physicians down

Home health agencies will have less control over new physician-related payment condition. And they’re hoping for some big changes to the face to face physician encounter requirement.

Although the mandate for the face to face encounter was in the Patient Protection and Affordable Care Act health care reform law enacted earlier this year, the CMS version of the requirement is stricter than the law requires.

Now, the new requirement will overburden referring physicians

This is likely if patients can even get in to see the physician. In many areas, it’s becoming more difficult to find physicians who are accepting Medicare, much less see them as frequently as required by the rule. In fact, it’s being said that access to care is going to be a major problem. Even those patients who have been in the hospital recently were probably not seen by their primary physician, but by a hospitalist in the inpatient setting.

An extended timeframe for the certifying physician to host a face to face encounter is important in the health care environment where there’re growing numbers of hospitalists, hospital-employed emergency rooms physicians, and a severe shortage of primary care physicians in the community.

Oftentimes patients are under the care of a specialist who’ll not follow the patient into general patient care in the home setting. And Medicare may not even pay doctors for those visits.

More work for physicians: Under the proposal, the physician’s documentation must describe how the clinical findings of that encounter supported the patient’s eligibility for the Medicare home health benefit. More specifically, the physician would document how the clinical findings of the encounter supported findings that the physician was homebound and in need of intermittent skilled nursing and/or therapy services. And the rule proposes that the physician must document it, even if her qualifying non-physician practitioner is the one who made the visit to update her of the patient’s condition.

What can be done: While you wait for the final rule, home health agencies can start educating referring physicians, other referral sources like hospital discharge planners, and caregivers about the ensuing regulation!