Face to Face (F2F) Documentation Changes for Physicians Go-Live: Monday, 10/3/16

Situation On August 3, 2016, Illinois began participation in a CMS Home Health Pre-Claim Review demonstration project. After 30 days in the demonstration project, Advocate at Home found that: More than 25% of admissions did not meet the CMS documentation requirements – we were unable to obtain necessary documentation, even 30 days post referral. Completing a separate Face to Face form, even the CMS form, is no longer acceptable.

Background CMS is Looking for Ways to Reduce Fraud Illinois and other demonstration states were chosen due to their high rate of Home Heath fraud. While burdensome for everyone, Advocate at Home has always collected documentation necessary to support Medical Necessity. We have done so to provide the right patient care and to protect Advocate and our physicians from allegations of fraud.

Assessment Advocate at Home, because of its size, presents a large ROI opportunity for the OIG and is at greater risk of an OIG audit. We expect one. Delays in receiving CMS required documentation at the time of referral: Affect patient safety and effective hand offs to Home Health Prevent Advocate at Home, and other Home Health agencies, from being able to bill for service provided to patients. Based on our initial experience, we will potentially face millions of dollars in write offs if today’s processes do not change. Have already caused area Home Health agencies to close.

New Requirements Beginning Monday Oct 3, 2016 Advocate at Home: Will require Face to Face (F2F) encounter elements be documented in the physician progress note. Separate F2F forms will not be accepted. Will require the following documentation at the time of referral. A physician order A physician progress note written by a Physician, Resident, APN or PA documenting all of the required F2F encounter elements (at Bromenn/Eureka APN and PA notes must be cosigned by a physician) Physician certification statement signed by the physician Name of community physician if certifying physician is not following the patient

Checklist for Home Health Referrals – Physician Documentation

Beginning Monday, October 3rd, 2016 Advocate at Home: Will require Face to Face (F2F) encounter elements be documented in the Physician, Resident, APN or PA progress note. Separate F2F forms will not be accepted. Will require the following documentation at the time of referral. A physician order A progress note written by a Physician, Resident, APN or PA documenting all of the required F2F encounter elements Physician Certification Statement signed by the physician

Physician Progress Notes Required Elements Date of visit (within 90 day prior/30 days after Home Health start of care date) Documentation that patient was treated during the encounter for the primary reason for Home Health services Narrative documentation – why patient requires skilled home health Narrative documentation – why patient is homebound – 2 reasons v. Physician, Resident, APN or PA signature, credentials and date

Physician Certification Statement Required Elements Physician certification statement signed by the physician “I certify/recertify that this patient is confined to his/her home (and meets homebound criteria) and needs intermittent skilled nursing care, physical therapy and/or speech therapy or continues to need occupational therapy. The patient is under my care, and a plan of care has been initiated and will periodically be reviewed by a physician. I (or an acute/post acute physician or collaborating NPP) had a Face-to-Face encounter with this patient on the above date, during which the primary reason for home health services was addressed. I have a clinical note (supporting documentation) documenting my encounter with the patient in the patient’s medical record to support certification and eligibility for home care, and will make it available to Advocate Home Health Services upon request.” “I am the certifying physician and will follow the patient in the community.” or “I am the certifying physician, but Dr. (Name and Credentials) will follow the patient in the community.” Certifying Physician Signature/Credentials Certification Date Physician Printed Name

Options for Documenting Use MeditechTemplate: Complete a Physician Progress Note using the Face to Face Encounter template Complete the Physician Certification Statement within the Face to Face Encounter template Use Meditech & enter your own Physician Progress Note Document the required F2F elements in your Physician Progress Note Physician Certification Statement can be included in the Physician Progress Note Or a paper Physician Cert Statement can be used with the electronic note Use another EMR/Medical Record Document the required F2F elements in a Physician Progress Note Or a paper Physician Certification Statement can be used with the electronic note At the time of referral, include a copy of the Physician Progress Note, and if not embedded in the note, a copy of the Physician Certification Statement

Using CareConnection for Documentation

Entering the CareConnection Order for Home Health

Step 1 – It starts with the order F2F documentation is triggered from the Discharge Planning Eval Adult order when Home Care Evaluation is selected as the reason for Discharge Eval:

Step 2 – F2F Documentation Alert An alert will appear indicating patient has an active order for HH and F2F documentation is needed; click on links to go to documentation

Documenting using PowerNote

Step 3 - Accessing PowerNotes 2. Choose the Miscellaneous Catalog Dropdown to select Home Health Face to Face 1. To access the notes Click on the Catalog tab within PowerNote 3. If ordering both Home Health and Home Oxygen, you must complete a PowerNote for both.

Step 4 - Placing Note Correct Folder Under Type, Right Click to have the pop up box appear. Check the All Note Type list to be able to scroll and find the Home Health Certification Folder. Save the powernote as a precompleted favorite – the folder type will stick for the note if this is done.

Step 5 – F2F PowerNote 1. Choose Date and Time from Calendar 3. Select One or More of the Homebound Reasons 2. Complete Clinical Reason/Diagnosis for Home Health i.e. Diabetes, Wound Care 4. Choose One or More of the Home Care Interventions 5. Identify outpatient physician managing patient

F2F Documentation Location Completed F2F form will appear in the Physician Documentation folder > Home Health Certification

PowerNote is Complete! When Certification field is clicked, documentation is added to Physician’s Progress Note in Patient’s Care Connection Record

Documenting the Certification Statement

Step 1 – F2F Documentation Alert An alert will appear indicating patient has an active order for HH and F2F documentation is needed; click on links to go to documentation

Step 2 - F2F Certification Statement 1. Enter the date the F2F Assessment was completed 2. Click “Yes” if you are physician following patient post-discharge or “No” if you are not 3. If you are not the physician following the patient post-discharge please enter in the physician who will follow the patient in the community

Step 3 - Accessing Reference Text Right click on box to left and select Reference Text for detailed examples of how to fill in the form

Step 4 – Resource Guide Reference text is a resource guide of how to complete the F2F documentation Summarizes home bound criteria examples (2 must be met) Provides examples of eligibility criteria

Questions?