Limited Compliance With Medicare's Home Health Face to Face Documentation Requirements

WHY WE DID THIS STUDY

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 with those beneficiaries occurred. This study (1) determined the extent to which physicians who certified home health care documented the face-to-face encounters, (2) described the nature of face-to-face documentation, and (3) assessed CMS's oversight of the face-to-face requirement.

HOW WE DID THIS STUDY

We reviewed 644 face-to-face encounter documents to analyze the extent to which the documents confirmed encounters and contained the required elements. We interviewed the four Home Health and Hospice Medicare Administrative Contractors (HH MACs) to describe how they ensure that home health agencies met the face-to-face encounter requirements. We also reviewed guidance documents and policies from CMS or the HH MACs about monitoring the face-to-face requirement.

WHAT WE FOUND

For 32 percent of home health claims that required face-to-face encounters, the documentation did not meet Medicare requirements, resulting in $2 billion in payments that should not have been made. Furthermore, physicians inconsistently completed the narrative portion of the face to face documentation. Some face-to-face documents provide information that, although not required by Medicare, could be useful, such as a printed name for the physician and a list of the home health services needed. CMS oversight of the face-to-face requirement is minimal.

WHAT WE RECOMMEND

We recommend that CMS (1) consider requiring a standardized form to ensure that physicians include all elements required for the face-to-face documentation, (2) develop a specific strategy to communicate directly with physicians about the face-to-face requirement, and (3) develop other oversight mechanisms for the face-to-face requirement. CMS concurred with all of our recommendations.