FTF: Three Steps to Compliance

2015 has already brought about a lot of changes in home health, including: implementation of OASIS C-1/ICD-9, further payment cuts, shifts and deletions in the case-mix points-, a nice relief in therapy reassessments, and needed relief in the face to face mandate. I was excited about the changes, but it seems it has brought up more uncertainty. We, as an industry do not have the time to remain uncertain-- the government is looking at FTF documentation with a very tight definition. There is an agency, right here in my own back yard, in Iowa, who unfortunately found this out this week, when they were mandated to pay back 5.63 MILLION dollars due to a lack of documentation of the FTF: http://www.justice.gov/opa/pr/iowa-home-care-company-pay-563-million-settle-false-claims-act-allegations

Here is what we know for sure -there are five things that must be documented, followed by a "real life How-to" get it done:

  • A FTF encounter occurred with a physician or NP/PA under physician

  • The FTF occurred within the timeframe (90 days prior, or within 30 days after SOC)

  • The FTF was related to the same reason for Home health

  • The clinical indicators why the patient has a need for skilled services

  • The clinical indicators why the patient is homebound.

In the past, the physician had to document all of this information in a narrative for the HHA, which was difficult for the agencies, as it was rarely done per CMS standards the first time through. As of January 1, 2015, we no longer need a narrative composed by the physician. Instead, this can all be found in a combination of the visit note, and supplemented by the HHA’s initial assessment narrative, if provided to the physician. Here is how we can most efficiently, meet this key compliance risk in three steps:

  • Intake: Request, obtain and review the visit note as proof of the FTF (visit, progress note, DC summary) upon referral. Ensure that the date and the practitioner are acceptable for the FTF standards. Next, note the reason for the FTF visit—is this the same reason the patient needs home health? This will be confirmed on the Initial Assessment. If not, another FTF must be arranged. This will meet at minimum 1, 2 and 3 above. Continue next steps if steps 4 and 5 are found to be weak in the documentation.

  • Initial Assessment: Write a narrative to describe

The clinical indications that support why the patient needs skilled services. This needs to be more than diagnoses only, but facts about exacerbations or recent changes in treatments or medications.

The clinical indications (not just generalizations, such as “taxing effort”, but provide the reason why, and the evidence assessed) that support why the patient is homebound

  • Office RN or Admitting clinician: Copy/paste the initial assessment narrative into the POC/485 to be sent to the physician.

This most easily would be provided in Locator 21. Label the area, at the beginning or end of the orders as “Additional Assessment to Support Eligibility and Face to Face Certification”

Your agency will want to add the sentence on the 485: "I certify a face to face encounter occurred on_____(DOCUMENTED VISIT DATE)____________"

Lastly, note to the physician "One copy for your records, and one copy for signature to and return to the agency"-- as CMS states this should all be in the physician record. You may even consider nothing this as a standard instruction on the 485.

These three steps ensure there is adequate information, as the HHA now has the ability to corroborate the physician’s documentation of the need for home health and the homebound status.