Late last week, VNAA sent a letter to the Centers for Medicare and Medicaid Services (CMS) urging them to delay the implementation of the new face-to-face documentation requirements until additional guidance can be developed and disseminated. This letter was a follow up to the face-to-face documentation guidance issued in the CY 2015 Home Health Prospective Payment System (HHPPS) Final Rule.
VNAA appreciates CMS' elimination of the physician face-to-face documentation narrative requirement. However, VNAA remains deeply concerned with the implementation of the new face-to-face documentation requirements. VNAA believes that the new requirements to rely on physician medical records and home health agency acquisition of physician record documentation will result in new areas of confusion for both referring physicians and home health agencies.
VNAA also asked CMS to develop, with input from all providers, a standardized form for use by physicians referring patients to home health services. Finally, VNAA encouraged CMS to educate Recovery Audit Contractors to ensure consistent application of standardized audit practices for face-to-face documentation requirements for home health services.