Recently, Healthcare Provider Solutions provided a free Home Health Coding webinar that covered updates that are coming soon with the ICD-10 diagnosis codes. During that webinar, there were many questions surrounding the section that was specific to the requirements of the Face-to-Face encounter and the coding aspect under Medical Review. We want to clarify that for the Face-to-Face to be valid at the start of care of a home health episode, the Face-to-Face encounter must have occurred within 90 days prior to the start of care or within 30 days after.
In addition to that, it must be conducted by an allowed practitioner, the document must be the encounter note itself from that visit, and it must be signed and dated. The care provider should have evidence that the primary diagnosis they are using in the home health episode was treated in that Face-to-Face encounter. For example, if the patient’s primary focus of care for home health is diabetes, diabetes must have been treated during the Face-to-Face encounter.
It is imperative to understand the significance of this not occurring because if you are under Medical Review you can have a denial, for not only the first 30-day period, but for subsequent periods, as well. The medical review process includes examining the patient’s initial certification requirements, which include checking when the patient was admitted, their primary diagnosis, and if the focus of care was treated during a Face-to-Face encounter.
As you continue through the care of that patient, the primary focus of care can change, then has no bearing on what was done during the Face-to-Face encounter.
To clarify the Face-to-Face encounter requirement, if a Nurse Practitioner is now allowed in your state to certify patients for home health and they are signing the plan of care and the Face-to-Face encounter did not come from the facility, the Face-to-Face encounter must be done by that Nurse Practitioner and cannot be done by another community physician. Again, the encounter can be done by a facility in which the patient has been directly referred to home health. If it is a community Face-to-Face encounter, it must be the Nurse Practitioner that is signing your care plan that conducts that Face-to-Face encounter.
Be sure that you continue to support the State and National Home Care and Hospice associations in their advocacy efforts to get the legislation passed to prevent decreases in home health rates through 2026.