Three Little Questions


Because the OASIS C database has become easier for you, Medicare has taken measures to ensure that 2017 offers some challenges in the way of OASIS C2.  In turn, we have taken measure to ensure that you understand at the very minimum the three new questions.  They come complete with their own conundrums, confusion and lots of reformatting and subtle shifts in definition.  It’s not as simple as it seems but it certainly isn’t out of your range of capabilities.

New Questions

Written by someone who is comforted by redundancy, MO1028 assesses (again) whether a patient has diabetes or peripheral vascular disease.

(M1028) Active Diagnoses– Comorbidities and Co-existing Conditions—Check all that apply

See the OASIS Guidance Manual or click here for a list of relevant ICD-10 codes.

  • Peripheral Vascular Disease (PVD) or Peripheral Arterial Disease (PAD)
  • Diabetes Mellitus (DM)

Additional guidance is not much different from coding conventions.  The diagnoses must be documented in the medical records produced by the physician or NP.

Having the condition is not enough to win a checked box.  The C2 manual states that the diagnosis must be active and the manual infers that ‘active’ means that there are orders written or monitoring of the disease process ongoing.

So, that’s two criteria –

  1. Does the patient have the condition and
  2. Is anyone watching it or writing orders for it.

Worth noting, if only for a laugh, the OASIS Guidance manual for the C2 dataset provides the following rationale for this question.  We are not kidding.

Disease processes can have a significant adverse effect on an individual’s health status and quality of life.

Section GG

Another new question is (GG0170C) Mobility.  The question occupies an entire page in the manual and if you are like me, it may take you a while to understand what they are truly asking.  Look the column in the body of the table to the very most right where it says something about the patient moving from a completely supine position to sitting on the side of the bed, feet flat on the floor with no backrest.   Everything else on the page refers to that single activity.

The answer reflecting the greatest impairment is 01 and a patient who can complete the tasks independently gets a 06 score.  Note that this is a new opportunity to make a careless error as the level of severity for every other question is reversed with 00 being the least impaired and the last possible response being the worst level of severity.

But there’s more.  The dataset asks for a goal.  If your patient is able to do this task at admission, it is not a problem.  Your initial response and your goal will be the same.  However, if some improvement is expected by the grace of your carefully crafted careplan, there will be a second response describing your patient’s expected ability upon discharge.  Take your best shot and don’t fret about not being able to predict the future.  It is true that all kinds of things can happen between admit/resumption of care and discharge but it is not reasonable to downgrade your goal in the event of a zombie attack.  On the other hand, remember that you are not so good that you can take a person who is totally dependent following a cerebral vascular accident and have them independent at discharge.

Getting Personal

Medicare wants to know the patient’s height and weight in M1060.

(M1060) Height and Weight—While measuring, if the number is X.1 – X.4 round down; X.5 or greater round up.

The Coders assume that you know how to round off numbers but Medicare does not and includes explicit instructions within the question.

Guidance for this question includes a helpful tip to measure your patient’s height and weight in accordance with the agency’s policies and procedures, which should reflect current standards of practice.  So, how many of you have a policy addressing how to measure the height and weight of a patient?

Assuming that such a policy exists in your agency, is it based upon sound clinical practice standards?  On your behalf, we have scoured the internet for practice standards for measuring height and weight and like the CDC Antropometry Procedures Manual.  Sadly, the manual refers to the Integrated Survey Information System anthropometry computer application (ISIS).   Do not be alarmed when you see this.

Also, when determining how height will be measured, plan on buying a stadiometer.  This is the apparatus seen in Physician offices that measures height.  Most of the affordable ones are wall mounted and we suggest that wall mounting is not recommended in your patient’s home environment.  Also, note that anything with brightly colored giraffes and ruler-like markings cheering on big boys and girls is not likely to be received well by adult patients or meet the practice standards. Call your medical supply company and plan to spend about $150.00 per portable stadiometer.

The Dash

There’s more – so much more but you have patients to see and notes to write.  We are going to leave you with information about The Dash.  This is not a simple dash as found in other places like a date or a social security number.  According to Medicare,

a dash (–) value indicates that no information is available, and/or an item could not be assessed. This most often occurs when the patient is unexpectedly transferred, discharged or dies before assessment of the item could be completed. CMS expects dash use to be a rare occurrence.

This definition is consistent throughout the manual.  When a dash value is an available option for questions, OASIS guidance generally indicates if the dash is a valid response.

For your convenience, we have uploaded some of these documents.  Hopefully, you will read them and then fill us in.  As always, we welcome your questions.  Maybe we’ll even answer a couple.

The OASIS Day


Friday, we posted a quiz about OASIS.  In the next week or so, we will publish the answers to all questions but one question is being answered incorrectly so consistently that we feel obligated to explain the answer as it is likely costing you money and lowering your outcomes.

56 percent of you missed this question.

Upon admit, Mr. Jones states he is feeling better after a trip to the MD this afternoon. He denies dizziness and is able to walk unassisted with a walker, get in and out of his chair and use the restroom independently. According to his wife, he suffered severe vertigo and vomiting most of last night until he was finally seen late this afternoon. On admission you document:

His ability to transfer based on your observation of Mr. Jones independently getting in and out of the chair.  (50% of you chose this answer)

His inability to walk or transfer, get to the toilet, or bathe based upon his severe vertigo last night and this morning.   (42% of you chose this response)

His wife’s assessment of what he can usually do . (8% of you put your faith in his wife)

He is not homebound because he was able to get to and from the MD.  (Nobody questioned homebound status)

In order to arrive at the correct answer, you must know two things.  For functional limitations such as walking, ambulating, transferring, etc., your response must be based on what is true on the day of the assessment and….

You must know what is meant by a ‘day’.

So, how did 58 percent of you answer this question incorrectly?  Maybe because you are unfamiliar with an OASIS day which is quite different the usual day.  We couldn’t possibly make this stuff up so we are going to cut and paste from the OASIS Guidance Manual, Chapter 1, page 6.  We made the text bold – don’t give CMS credit for that:

Understand the time period under consideration for each item. Report what is true on the day of assessment unless a different time period has been indicated in the item or related guidance. Day of assessment is defined as the 24 hours immediately preceding the home visit and the time spent by the clinician in the home.

In the scenario mentioned, the patient had been violently ill all night and most of the day until he went to the MD in the afternoon.  The same manual (OASIS Guidance Manual) on the same page (chapter 1; page 6), states:

If the patient’s ability or status varies on the day of the assessment, report the patient’s “usual status” or what is true greater than 50% of the assessment time frame, unless the item specifies differently.

Without counting minutes and seconds, this means that if Mr. Jones spent 12 of the 24 hours in question unable to walk, transfer, get to the restroom, etc. safely, his OASIS assessment should reflect it.  Assuming his night began as late as Midnight and he continued to be violently ill until the afternoon when he saw the MD, the time span covered more than 12 hours.

Your answer, therefore should reflect his epic vomiting and vertigo.

Here’s another explanation of how to assess the intoxicated patient which should be considered in Louisiana as Mardi Gras gets under full swing.

Why This Matters

If this was a rare and unusual situation, it would not matter very much but it is not – especially on admission.  Anesthesia, pain meds following a procedure, reactions to medications all have the potential for taking a patient out of commission for a day or so, prompting a physician to order services to monitor and treat the patient.

With only 42% of you answering this correctly, it didn’t seem right to wait until we publish the rest of the answers to prevent further damage to your published outcomes or payment.  Congratulations to everyone who got this question right, including Lori Hopwood of Lane Home Health – a 4.5 Star agency right here is South Louisiana.  Laissez bon temps rouler in Cajun Country.

Targeted for ADRs


Every so often, Palmetto posts a list of the claims that will be of interest to them on their website. This is the list that was published on August 4.

Note the last letter of the HIPPS code. The letter ‘L’ indicates 16 – 17 therapy visits and the dreaded ‘K’ means that 20 or more therapy visits are scheduled. Only one of the edits is for therapy below 14 visits. In that edit, Palmetto GBA is looking for the lowest clinical and functional scores together with therapy.

Palmetto is asking why a patient who appears to be clinically stable and can walk, talk, bathe, transfer and dress themselves needs any therapy. It’s a good question. There could be a perfectly legitimate explanation but if it is not documented well, you are looking at a denial.

Pretty much all episodes with 20 or more therapy visits are being scrutinized. These are the expensive claims and people who are ‘gaming’ the system will often use high utilization as a method to do so. This does NOT mean that a patient should not receive 20 therapy visits if needed. For most agencies, these episodes will be few and far between.

16 and 17 visits are very profitable as well even if the dollar amount is not the same. The profit starts to drop off at 18 and 19 visits until 20 visits are made.

All clinical documentation should support the services billed but in an agency where staff is limited or compromised at time of billing, claims with these HIPPS codes might be prioritized for review prior to dropping claims.

1BGP* 0 – 13 Visits, Lowest Scores in the Clinical and Functional Domains and Maximum Score in the Service Domain
2BGL* 16-17 Therapy Visits, Moderate Score on the Clinical Domain and Moderate Score on the Functional Domain
2CGL* 16-17 Therapy Visits, High Score on the Clinical Domain and Moderate Score on the Functional Domain
2CHL* 16-17 Therapy Visits, High Score on Clinical Domain, High Score on Functional Domain
5AFK* 20 or More Therapy Visits, Low Score on the Clinical Domain and Low Score on the Functional Domain
5AGK* 20 or More Therapy Visits, Low Score on the Clinical Domain and Moderate Score on the Functional Domain
5AHK* 20 or More Therapy Visits, Low Score on the Clinical Domain and High Score on the Functional Domain
5BFK* 20 or More Therapy Visits, Moderate Score on the Clinical Domain and Low Score on the Functional Domain
5BGK* 20 or More Therapy Visits, Moderate Score on the Clinical Domain and Moderate Score on the Functional Domain
5CGK* 20 or More Therapy Visits, High Score on the Clinical Domain and Moderate Score on the Functional Domain
5CHK* 20 or More Therapy Visits, High Score on the Clinical Domain and High Score on the Functional Domain
All Aggregate Length of Stay and Disbursement/Beneficiary
All Home Health Services

 

Nina Pham


 

The CDC, among others, have suggested that perhaps more training is needed to ensure that direct health care workers are properly using protective equipment.   According to that line of thought, poor Nina Pham simply did not know what she was doing when she picked up a touch of Ebola from her patient.  If only she had more education on how to put on gloves and a gown, this whole disaster could have been avoided.

I think not.

I posted my dismay regarding re-educating nurses on FaceBook and was amazed at how smart my friends are.

One non-nurse, Michelle said that education was a way to protect the facility.  In other words, when a policy is violated, the hospital is able to assure any surveyor or lawyer that they did, indeed, provide the education and training and have therefore met their responsibility.  Sadly, a successful healthcare facility (and by successful, I mean isn’t closed down) must cover all bases to minimize damages.  I would probably waste time and resources re-teaching PPE, too if I had to make the decisions.

She also pointed out that maybe protocols are not strictly enforced when the risks are lower which could lead to bad habits.  I agree.  Ever notice how MRSA is already a problem when we start monitoring hand hygiene?  (I love that.  Hand hygiene – soon there will be an aisle in the supermarket for hand hygiene products instead of soap, antibacterial gel and hand lotion.)

Lisa Selman Holman pointed out how very miserable PPE is to wear.  She is right.  It is hot and sticky, nothing fits right and it is ugly in the most unforgiving way.  I have yet to figure out how looking like Big Bird assists in the infection control process. Healthcare workers, especially those with a fashion sense, can’t wait to take it off.

If ever there was a time to spend money, this would be it.  Athletic clothing manufacturers have done amazing things with sports gear.  It seems like a clothing manufacturer who exists because they make comfortable, functional clothes that can wick away perspiration, kill enough germs to smell good and keep a body warm in water might be able to help design something comfortable, disease proof, easily taken on and off  with the assistance of an infection control specialist.

Sara Kawaguchi came up with the idea of having two people involved – one present simply to observe.  I love this idea and it is cheap to do when considering the stakes.  Having never met Miss Pham, I can only assume that she didn’t tear a glove, look at it and say, ‘Oh darn,’ and carry on with restarting an infiltrated IV line.   If she breached protocol, it was likely unnoticed by her.

My cousin, Steve, is a physician and his response was simple.

1) we are human
2) we make mistakes
3 there is no room for a mistake here, in flight or in surgery

There’s a lot of truth in that but we can minimize mistakes.  Even the world famous Quality Assurance plan designed by Toyota, Six Sigma refers to only six errors in a million.  When it comes to Ebola, nobody wants to be one of the six.

The Checklist Manifesto by Atul Gawande is written by a surgeon who almost killed a patient because he forgot to do something very simple and standard prior to surgery – type and match blood.  After this near catastrophe that left his confidence shaken, he set about researching how to prevent errors.  It turned out that aviation history was marred by the crash of the first B17 in which several people died.  It almost took Boeing aircraft out of the game completely.  The solution included a checklist which enabled the (highly skilled and trained pilots) to fly 12 planes a total of 1.8M miles without incident.  It is now used universally.

Checklists are not designed to educate anyone.  If you have ever turned in visit notes only to find out that you forgot to write a narrative because you were interrupted, you are prone to human error.  If you have ever been called about a bill you know you paid only to find the stamped envelope in your purse, you could have used a checklist.  They are designed to let you pick up where you left off in the event something slips your mind, you are preoccupied or there is chaos all around you.  They ground and center the user.

There are undoubtedly numerous approaches to improving the safety of healthcare workers but re-educating the staff in a critical care unit on how to put on and take off PPE is an intervention for the hospital – not the nurses.  Don’t tell me that the staff in an intensive care unit requires more schoolin’ to put on gowns, masks and gloves.  Make them more comfortable so they aren’t urgently ripped off like they were on fire the minute you clear the room.  Have someone else watch.  Use a check list.  Doing more of what was done in the past because it didn’t work doesn’t quite make sense to me.

What the healthcare staff needs the most is a cure for Ebola.  When it comes to caring for a patient with Ebola, especially at the end of life, perhaps the most important changes will come about from the staff who were actually there doing the job.  If the blame game stops and the focus is directed to increased protection of healthcare workers, why not consult that handful of clinicians who are the only ones in the United States to have cared for Ebola patients in US hospitals?

I know that you join The Coders in wishing Godspeed to Nina Pham’s recovery.  She was able to be there for a patient isolated from his family and friends when he needed them the most.  People like Nina Pham do not put their own lives on the line for a paycheck.  She has a calling and I pray she will be back at work sooner than later.

Also,  let’s not forget that Nina Pham is not alone.  A few dozen other healthcare workers who took the same risk as Nina Pham and so far, have been free of symptoms.  These include the staff in Dallas as well as Nebraska and GA where two other Ebola patients have been treated.  They are no less heroic because they have not contracted Ebola; they just haven’t made the news and I hope they don’t any time soon.

Elderly Abuse?


A colleague of mine got a couple of phone calls from patients terrified they were going to be admitted to a nursing home.  Two men had come by with a three page list of questions and started asking very personal questions about whether or not they can get in a car, if they can go out to eat and how often their nurse visits.

My colleague reports in his email to me:

“They are not leaving cards or anything. One savvy patient finally got all their information and called us with it.”

and

“One patient was not home when they stopped at his house so they talked with and asked his neighbor questions.”

The men in question were employed by Jackson Dunham Sato & Associates. If you glance through the bio’s on the left sidebar, you will see that essentially all of the managers, partners and associates mostly come from one of two federal governing bodies – the OIG, and CMS (Medicare).  In fact, if you go to the top bar and click on careers, you will find that they are not interested in you if you are not:

  • A current or former Office of Inspector General Auditor/Investigator with healthcare experience
  • A current or former CMS employee who has been involved in program compliance/integrity oversight

At least you don’t have to worry about them poaching your employees.

I realize and you probably do, too, that all of this information is second and third hand.  In order to be responsible, I emailed each of the three senior partners and have not received a response.  The questions asked of them were:

  1. Is this your usual policy regarding identification of your investigators on home visits?
  2. Would it be possible to have your folks dress down; perhaps wear scrubs?
  3. What explanation is given to the patients if they do not ask for identification?  Do the investigators allow them to make assumptions no matter how terrifying?
  4. Do you understand that a patient fearful of nursing home placement might exaggerate their functional abilities?
  5. Could you or do you leave some sort of documentation with the patients?  Patients are calling agencies who are unaware of your presence and cannot offer the patients any reassurance because they do not know who interrogated their patients.
  6. Do you ever send clinicians out to the home to verify medication use and evaluate gait and balance?
  7. Do you do a mental status exam on the patients?  Many patients with Alzheimer’s Dementia and other organic brain syndromes appear as right as rain the first couple of times you meet them.
  8. How do you choose the providers you will be investigating?   Are they assigned to you by Health Integrity?  Do you have access to databases that you can mine for data?
  9. How are you paid by Health Integrity?  Is your payment predicated in any way on recouped monies or arrests?

I have not gotten a response but Health Integrity, LLC confirms that Jackson Dunham, Sato and Associates are a ‘partner’ on their website.  Health Integrity, LLC is the Zone Program Integrity Contractor (ZPIC) for CMS Regions 2 and 4.  Combined, these two regions encompass  Alaska, Arizona, Colorado,  Idaho, Iowa, Kansas, Missouri, Montana, Nebraska, New Mexico, Oklahoma,, North Dakota, Oregon, South Dakota, Texas, Utah, Washington, and Wyoming.

Regardless of an agency’s guilt or innocence, our elderly deserve to be treated with more respect than they have been shown by Jackson Dunham Sato and Associates.  I question the motives of a firm that resorts to intimidating elderly patients and possibly encouraging them to exaggerate their functional abilities in order to ‘prove’ that a patient is not homebound.  Are they genuinely concerned about the welfare of our elderly and protecting the trusts that fund Medicare or are they simply trying to satisfy a requirement for contract renewal, bonus pay or something else?

I can sit at my desk a thousand miles away from a patient and know whether or not their homebound status is questionable.  It is tedious to read every note, every MD clinic visit and OASIS assessment to look for discrepancies and the tell tale signs that the patient does not fit the description in the care plan and the visit notes.   It is not the most glamorous job in the world, I assure you but it can be done without instilling fear of unwanted nursing home placement in elderly people.  Even if a visit has to be made in order to make a final determination, it does not require rudeness or fear.  Even if the investigators are accompanied by a nurse from the agency, it is unlikely that a nurse would be able to influence the patient to lie.

The very best consultant and the very best lawyer cannot help you if you are determined to play outside of the conditions of participation and conditions for payment.  We’ll take you money and do our best. If it is a question of inadequate documentation versus fraud, we can generally help but there is not much we can do if you simply choose to sidestep the rules.

Nobody who works for Medicare or is contracted or subcontracted by Medicare seems to understand that good providers have even less tolerance for the fraudulent providers than they do.  If they would make just the tiniest effort to work with the majority of providers who are good, they might learn a thing or two and then it wouldn’t take years and hundreds of millions of Medicare dollars gone before they caught up with the truly bad players.  At that point, they could offer more frequent education to those providers who take compliance seriously.

If your patients have had visitors or if you have had experience with Jackson Dunham, Sato and Associates, please email me privately and let me know.  As always your comments are welcome below and if I get a response from Jackson Dunham, Sato and Associates, I will be sure to let you know.

One last thing….. if I ever hear of you intimidating a patient, watch out.  I am not nice when I hear of an elderly person treated with anything less than respect.

Hospice Coding


coding wordle 2

 

72 percent of hospice claims list only one diagnosis.  The diagnosis used most often is Debility. The third most frequently used diagnosis is adult failure to thrive. 

That means that upwards of 75 percent of hospices may have some real problems soon.  The requirement that hospices adhere to the ICD-9 coding guidelines is not new.  It is written into the original 1983 hospice guidelines and CMS is very much aware that hospices are not following the long established rules of coding.

Hospices have responded by building cheat sheets and lists of common hospice diagnoses.  It’s a great idea but it probably won’t work.  It didn’t work for hospitals in the 90’s or home health agencies after their prospective payment system was refined in 2008.  To this day agencies that depend on untrained nurses to code are losing money by insufficient coding or worse, getting denied because of invalid codes.

The biggest mistake that home health agencies made all those years ago after PPS was implemented was not taking coding seriously.  With four exceptions, the ICD-9 coding performed by an agency did not affect payment.  As such, diagnosis coding was not taken very seriously by home health. 

That turned out to be a mistake. Diagnoses that required significant resources to treat were not included in future updates to the payment system.  Incorrect, poorly specified diagnoses were included but when coded correctly, they did not add to the reimbursement.

I am not going to pretend that I am psychic and charge you for my insight into the future.  I can only say that I see this happening to the Hospice Industry in the not-so-distant future.

How could this stubborn insistence on following the rules be any worse, you ask?  It comes right as the rest of the world is transitioning into ICD-10 coding.  That’s right.  By the time you get the hang of ICD-9 Coding, the rules of the game will change.

It’s almost as though Medicare has taken up our cause as their own and has begun emphasizing the value of our coding services.  Thank you, Medicare for the plug.  Can we talk about the face-to-face requirement, now?

If you do not want to outsource coding, there are other options (but none as good as contracting with us or another reputable company).

  1. If your hospice has common ownership with a home health agency, remember that this is not new to them.  Make some kind of arrangement with them. 
  2. When you are recruiting nurses or billers, put coding on the top of the list of preferred skills.
  3. Go online and look for certified coders.  Remember, coders do not have to be nurses.
  4. If there is a school that offers RHIT certification in your area, offer a student internship.  You might end up with the employee of a lifetime or a dud.  It is worth the gamble because they are trained in coding, electronic health information, etc.   
  5. Outsource ICD-9 coding and focus on investing in ICD-10 coding preparation for your staff. 

Remember, people do not wake up one morning and try as hard as they can to thrive and fail.  If you cannot come up with a good underlying reason, expect denials.  Not being paid fairly could easily be the result of poor coding which might lead to a poor outcome for hospices that go the extra mile to ensure patients and their families are comfortable at the end of life.  It takes resources to provide the kind of care that matters.  Don’t cheat your hospice or your patients by failing to take this seriously.

As always, Delaine and Jackie can be reached via email or you can call 337-654-7934. 

Face to Face Answers


If you have not already taken the quiz on Face to Face encounter for home health, please do so by clicking here before continuing.  The answers are as follows.

When should the face to face encounter occur?

The face to face encounter should always occur within the 90 days prior to admission for home health services or within 30 days following the admission.  However, if a physician visit in the prior 90 days was not for reasons related to home health services, an additional visit is required related to home health services.

Who may sign the face to face encounter? 

The physician who orders home health services must always sign the face to face encounter. 

How can you  best assist the physician in the face to face process?

The best way to assist the physician is with education.  Not only do physicians resent the additional paperwork but if your agency is following the guidelines, there is a really good chance that you are competing against other agencies that complete the face to face documentation for the physician.  By educating your referral sources, you are also protecting them from inadvertently participating in fraudulent activity. 

A physician documents that a patient is confined to the home because they do not drive.  What should you do?

The correct answer is to visit with the physician and ask him to document why the patient does not drive. Assuming the reason that the patient does not drive is related to their health and not lost keys, the physician will hopefully understand homebound status a little better after your discussion.

Which of the following is not true about Face to Face Documentation?

Although it seems redundant as it is repeated so many times, a common reason for face to face denials is that the physician who certified the plan of care did not sign the face to face document. 

Which of the following is not true about Face to Face Documentation?

Yes, there are two questions that read the same.  This refers to question 8 and the only untrue answer is that the face to face should not be sent by the hospitalist while the referring physician sends the certification.  The face to face document is considered a part of the initial certification.

Everything else is true.  The physician may use drop down boxes in his or her software if they adequately describe the patient.  The entire face to face document may be computer generated and recent denials because the date of the encounter was not handwritten are erroneous on the part of the MAC. That is not a requirement.

Which is true regarding the physician narrative?

The correct answer is that it should contain the patient’s condition at the time of the encounter.  When the face to face documentation differs from the agency documentation, a denial may result.  For instance, a physician states the patient needs therapy and upon admission, the patient refuses therapy.  Because the patient is new anticoagulation therapy, the patient is admitted from services.  This type of discrepancy has resulted in numerous denials.

When is it acceptable to bill without a face to face encounter?

The only time it would be considered acceptable to bill without a face to face encounter would be if the patient dies prior to the 30th day and the agency can show that efforts were in progress for the patient to see the physician.  Please note we are not suggesting that you introduce your patient to the great hereafter if the patient does not go to the physician as planned.

When the referring physician is unavailable, the Medical Director may sign the Certification and Face to Face documentation.  (T/F)

False.  The only time the Medical Director may sign the face to face documentation is on those occasions when the patient was seen and referred by the Medical Director.  These referrals must fall under the confines of Stark and Anti-kickback laws that prohibit the sale of patients.

The face to face documentation is required on all patients admitted to a Medicare certified agency regardless of payor source.  (T/F)

This is actually a trick question because Medicare clearly states that only Medicare patients require a face to face document.  Try telling Humana that.  They are denying claims based on the language in their contracts with agencies that all Medicare rules apply to Humana patients as well.  Get one on everyone just to be safe.

The physician who signs the plan of care must also sign the face to face encounter. (T/F)

If you started this Face to Face adventure believing anything else and you now know better, you have not wasted your time. 

What is true about face to face documents prepared by a hospital physician who then handed off the patient to a community physician?

A final, often overlooked reason for denial is that any document that is used as the face to face document must be clearly labeled as the face to face document.  If the physician merely staples a discharge summary with all the pertinent parts on it to the plan of care, it will not suffice.  ALF’s often have a form that contains al of this information but if it is not labeled as a face to face, it will not count.  Finally, some hospitals have software that generate a document that looks like a face to face without being labeled.  This is an easy fix and I trust you will never be denied for an unlabeled face to face in the future.

How did you do?  Did you learn anything?  Feedback is always welcome and criticism is swallowed whole when offered with our best interests in mind.

The Coders want  you to get paid.  Together with our affiliated companies, HCMB billing and Haydel Consulting Services LLC, we are prepared to offer billing, coding and clinical consulting services tailored specifically to your needs.  Contact us today by email or click here to get your questions answered.  And be sure to subscribe to our blog so you won’t a single post.