A recent Medicare Learning Network Article, MLN Matters SE1405 provides guidance on how to avoid face-to-face denials. Documentation of the need for skilled care and homebound status is a key component to avoiding denials. The narrative, written by physician/non-physician practitioner or allowable staff, does not have to be lengthy but must include substantial clinical data that clearly identifies the need for a registered nurse or licensed therapist to provide needed services in the home.
Another common question related to face-to-face pertains to the definition and role of the certifying physician. CMS states "A physician must order Medicare home health services and must certify a patient's eligibility for the benefit." There is a common assumption that "the certifying physician" is the one signing the plan of care. However, it could be a hospitalist or emergency room (ER) physician who could complete the face-to-face documentation and certify that the patient qualifies for home care. But the physician who signs the plan of care should be the one who will take responsibility for the patient throughout the 60-day episode.
The MLN article also provides examples of sufficient and insufficient narratives the physician's office could provide. To see these examples, click here.