OIG Report on Medicare's Home Health F2F Requirement

The Office of the Inspector General (OIG) released a report last week on the Limited Compliance with Medicare's Home Health Face-to-Face Documentation Requirements which shows a lack of compliance with the Medicare requirements. The Patient Protection and Affordable Care Act (ACA) requires that physicians (or certain practitioners working with them) who certify beneficiaries as eligible for Medicare home health services document, as a condition of payment for home health services, that Face-to-Face encounters (F2F) with those beneficiaries occurred. One part of the study looked at the extent to which physicians who certified home health care documented the F2F encounters. The study cites that 32 percent of home health claims that require F2F encounters did not meet the requirement, resulting in $2 billion in overpayments.

LeadingAge NY has repeatedly heard from members the difficulty they have encountered in having physicians complete the F2F requirements and the negative impact it has for their agency. It is encouraging to see in the report that Home Health Agencies (HHAs) are frustrated with the F2F requirements and that OIG recognizes HHAs are held financially accountable for failure to obtain F2F documentation but have no authority to compel the physicians to complete the form or to complete it in a timely manner. LeadingAge NY has raised this issue several times with the Department of Health and our colleagues at LeadingAge national. 

OIG has three recommendations:

• Consider requiring a standardized form to ensure that physicians include all the elements for the F2F requirement;
• Develop a communication strategy to ensure physician compliance with F2F; and
• Develop other oversight mechanisms to ensure compliance.

According to the report, CMS agrees with all three recommendations.

OIG found that ten percent of claims were missing F2F documentation at a cost of $605 million and that of the F2F documentation submitted, 25 percent were missing one of the required elements. The most common missing element was the signature of the certifying physician. Seventeen percent of the F2F documents were signed by persons other than the certifying physician. Table 1 on page 9 of the report shows the home health documents that did not meet the Medicare requirements.  

LeadingAge NY will keep members posted on our continued advocacy and as more information becomes available.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871