In this Question of the Week, Melinda A. Gaboury, CEO answers a question related to Face-to-Face and Plan of Care Requirements.
Q: Can we address a couple of questions to make sure we’re interpreting the new rules correctly? I also want to go over operative note using it as F2F encounter. I also use a statement whenever the certifying physician is different from the F2F physician. I receive many referrals from inpatient physicians and want to verify if associates can also sign the POC when another associate performed the F2F. For example, a physician performed the F2F but his associate whom, is the physician assistant, will be signing POC.
A: The only change to the face-to-face encounter rule is that any allowed practitioner can perform the encounter rather than only the certifying provider or directly referring facility. The certifying provider will need to certify the date of the compliant encounter in the certification statement.
When an operative note is used as the face-to-face encounter, it must be accompanied by a pre-op note, or post-op note to ensure that the condition being treated in home health is addressed and also because the patient is unable to participate in a two-way “face-to-face” encounter when under anesthesia. An operative note alone will not be compliant since it does not meet the requirements.
The certifying provider must include the date of the compliant F2F encounter as part of their certification statement.
The F2F encounter may be performed by any qualifying practitioner and is not limited to the certifying practitioner or a practitioner from a facility admission. Be very clear that regardless of who provides the F2F, it must still meet all the requirements – Within 90 days prior to the Start of Care or within 30 days after. It must be an actual visit note from the practitioner that is signed and dated. It must contain support for skilled need for home health and homebound status. It must also document treatment to the primary reason for the home health admission.
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