CGS Joins Palmetto In Review of Face-to-Face Documentation
Tuesday, June 18, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On June 7, CGS announced widespread reviews of face-to-face (F2F) documentation for home health providers. CGS is the second Medicare administrative contractor (MAC) to take an in-depth look at home health face-to-face encounter documentation, Palmetto GBA began a similar review in May, read more on their decision by clicking here.
The review was prompted by numerous errors both CGS and the Comprehensive Error Rate Testing (CERT) review contractor identified. The topic code for the review is “52xxT” (with “xx” identifying various numbers) on claims selected for the probe. The probe will only be conducted for start of care home health claims, equally distributed across the CGS provider community.Once selected, the claims will be reviewed for not only F2F encounter documentation but also medical necessity compliance with all Medicare coverage guidelines, correct billing and coding.

The most common errors identified by the CERT contractor are: 1) insufficient documentation of clinical findings to show the encounter was related to the primary reason for home care and 2) description of why the patient was homebound and required skilled care.

CGS offers these tips to help providers prepare for the review:
  • Check for claims in additional documentation request (ADR) statusin the fiscal intermediary standard system (FISS) at least weekly.
  • Have a clinician review face-to-face documentationbefore you submit it to CGS.
  • Mail in documentation within 30 daysof the request to prevent timeliness denials.
CGS also provided a list of frequently used statements or items considered insufficient for documentation. To review these and the entire notice from CGS, please click here.

CGS is the Home Health and Hospice MAC in the states of Colorado, Delaware, DC, Iowa, Kansas, Maryland, Missouri, Montana, Nebraska, North Dakota, South Dakota, Pennsylvania, Utah, Virginia, West Virginia, and Wyoming.
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