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Home health providers seek Medicare face-to-face encounter fix

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Home health care providers are trying to persuade Congress to reform part of the system Medicare uses to decide whether homebound enrollees really need to get care at home.

Sarah Meyers, executive director of the Oregon Association of Health Care, has asked members of the House Energy and Commerce health subcommittee to overhaul the Medicare “face-to-face encounter” requirement.

To prevent waste, fraud and abuse of home health care benefits, Medicare requires the enrollees who are getting home care to show they have had a face-to-face encounter with a physician before getting the care.

Most home health care providers agree on the need for the patients getting the care to have physician oversight, but “this important safeguard has been implemented with impossible-to-meet documentation requirements,” Meyers said in written testimony submitted for a subcommittee hearing on several proposals for changing Medicare.

The subcommittee looked at draft of the Medicare face-to-face encounters bill, which does not yet have a bill number; H.R. 556, a bill that would change Medicare physical therapy rules; and H.R. 1934, a bill that would establish a national medical home test program for Medicare enrollees who have cancer.

Rep. Greg Walden, R-Ore., is lining up support for the face-to-face encounter draft.

Medicare program managers have complained that they’ve had problems with unnecessary use of home health care, and poor documentation of the need for the care.

See also: Watchdog: Doctors skimp on home health reviews

But Meyers say Medicare claim reviewers have contributed to the problem by creating confusing, conflicting documentation requirements and claim review procedures.

In one case in Oregon, for example, a claim reviewer denied a claim based on an authorization from a Veterans Affairs (VA) doctor, simply because the doctor’s electronic signature showed up in a “referring provider” field. The VA said that it was using a national form approved by the Centers for Medicare & Medicaid Services (CMS) that could not be changed, but the reviewer refused to accept the authorization provided on that form, Meyers said.

In another case, a doctor wrote the date as 1/10/14 at the top of a paper form but put 1/14 next to his signature. A reviewer denied the claim simply because of the conflicts between the way the date was written at the top of the form and next to the signature, Meyers said.

Meyers said the Walden bill would improve the situation by creating a standardized face-to-face encounter documentation form.

The Walden proposal would also require CMS to provide broad education about the form, to improve the consistency of the documentation and documentation review systems, Meyers said.


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