CY 2011: Physician Signatures on Lab Requisitions, Face-to-Face Encounters, and Therapy Updates

LABORATORY REQUISITIONS

Though CMS states there is delayed enforcement until April 1, 2011, home health agencies should be ready to hear from laboratories regarding the new CMS requirement to have physician signatures on requisitions. Agencies have been required to obtain orders for lab tests. CMS now requires signatures on requisitions in order for the laboratory to be paid.

Some agencies have expressed concern that laboratories may attempt to have home health agencies obtain the signatures for them, thus increasing the agency’s paperwork. The industry trends toward improving alliances with acute care centers and others may need to stretch to include laboratories. Your comments would be appreciated. We ask, could a dual purpose form be developed that would save everyone time?

FACE to FACE ENCOUNTERS

Face to Face encounters also have a delayed enforcement component. Agencies are expected to be obtaining the encounter information. How is that progressing? What roadblocks or obstacles have you encountered? The enforcement delay is for the purpose of providing time for agencies to refine the process.

Remember, the physician must certify that the patient’s clinical condition supports the home health need for skilled services. The physician must document the clinical findings (no canned choices to circle) and they must also note the patient is homebound. Agencies have reported physician reticence with the new requirement, but CMS is increasing educational activities for the physicians. If you have suggestions, we would appreciate your comments.

THERAPY

While trying to refine processes for face to face encounters and lab requisition signatures, home health agencies should be planning the processes to track qualified therapist and therapy assistant visits, especially those visits required for the 13^th and 19^th visit that must be completed by the qualified therapist.

CMS clarified the language noting that assessments required APPLY TO EACH THERAPY DISCIPLINE individually, not in combination as most industry experts had believed from the text written.

Qualified therapists will also be required to reassess, measure, and clearly document patient progress at least one time every 30 days. How is your agency dealing with this process?

Tags: CY2011, Face to Face Encounters, Home Health, Medicare

This entry was posted on Tuesday, January 25th, 2011 at 10:27 am and is filed under CY2011, Face to Face Encounters. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.