Good Morning MFS Bloggers, CMS recently revised the its OASIS-C Guidance Manual for Calendar Year 2011. The revisions and updated errata list are now available on the CMS site, https://www.cms.gov/HomeHealthQualityInits/14_HHQIOASISUserManual.asp, and are available for download:
OASIS-C Guidance Manual Errata (December 2011)
and OASIS-C Guidance Manual (December 2011)
Have a great day!
Chris
Wednesday, January 11, 2012
Wednesday, January 4, 2012
DECEMBER 8, 2011: CMS CLARIFIES FACE-TO-FACE REQUIREMENTS
Good Morning MFS Bloggers, In a December 8, 2011 CMS Listserv Update, CMS clarified its policy on its face-to-face documentation requirements. CMS stated as follows: “In the case of patients admitted to home health following an acute or post-acute stay, the BPM language allows for one physician to sign the certification and face-to-face documentation, while a different physician can sign the plan of care. If the face-to-face encounter documentation and the CMS-485 form collectively satisfy all of the certification and plan of care content requirements as defined in Chapter 7 Section 30 of the BPM, Medicare contractors shall accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the certification, face-to-face encounter, and plan of care requirements. In this scenario, the certifying physician is the acute or post-acute physician, has initiated content on the CMS-485, and has completed and signed the face-to-face encounter documentation. The physician who signs the CMS-485 assumes care for the patient’s home healthcare.
Additionally, it has come to our attention that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient. CMS has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician.
For claims that have been previously denied for not having met face-to-face requirements in the scenarios described above, upon receiving a request from the home health agency for reopening of the claim, CMS contractors have been instructed to reopen and determine if face-to-face requirements have been met, due to their meeting the criteria described in the instruction described above. However, a determination that face-to-face requirements have been met would not result in an automatic pay of the claim. Contractors must subsequently perform a complete and full review to determine if payment should be made.
In summary, assuming all content requirements of the certification and the face-to-face documentation are otherwise met, in the case of patients admitted to home health following an acute or post-acute stay, Medicare contractors have been instructed to accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the requirement of the certification, (which now includes the face-to-face encounter).”
Wishing you all a happy and healthy 2012.
Christopher A. Parrella, JD, CHC, CPC, CPCO
Additionally, it has come to our attention that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient. CMS has not mandated the acute or post-acute physician to follow a specific documentation protocol to hand-off a patient to the community physician.
For claims that have been previously denied for not having met face-to-face requirements in the scenarios described above, upon receiving a request from the home health agency for reopening of the claim, CMS contractors have been instructed to reopen and determine if face-to-face requirements have been met, due to their meeting the criteria described in the instruction described above. However, a determination that face-to-face requirements have been met would not result in an automatic pay of the claim. Contractors must subsequently perform a complete and full review to determine if payment should be made.
In summary, assuming all content requirements of the certification and the face-to-face documentation are otherwise met, in the case of patients admitted to home health following an acute or post-acute stay, Medicare contractors have been instructed to accept a CMS-485 form signed by the community physician who assumes oversight of the patient’s home healthcare with an addendum containing the face-to-face encounter documentation requirements signed by a physician who cared for the patient in an acute or post-acute setting, to satisfy the requirement of the certification, (which now includes the face-to-face encounter).”
Wishing you all a happy and healthy 2012.
Christopher A. Parrella, JD, CHC, CPC, CPCO
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