Assessment tools for 2011, Face to Face Encounter, and Final CMS 2011 Changes
Merry Christmas and Happy New Year!
So this E-Zine we wanted to provide some tools that we believe you and your agency would find helpful for 2011. As a reminder you can always visit our blog site for the latest Home Health industry information here 
Also we have a growing selection of educational videos on YouTube and our website available to you free here (selectdatainc channel page).
Audit Tools to Protect against RAC, MAC, Z-PIC audits…
It seems that everyone is facing an audit. The best protection is adhering to regulation and following agency policy and procedures. But agencies need to know if procedure is being followed.
This month we are presenting a few audit tools for you to consider. The first is an extensive tool that you may wish to consider for quarterly reviews or as a review before dropping a claim.
For the next few weeks we will be offering a series of tools for your consideration. We believe you may find them helpful.
Download the following tool below (both in XLS and PDF formats).
Chart Audit Tool Excel
Chart Audit Tool PDF
UPDATED for 2011: Chart Audit Tool (2011 Ready) Excel
Infection Risk Assessment Tool
This Infection Risk Assessment Tool offers an easy and quick review of client predisposing factors that aid in preventing infection. The clinician has the opportunity to evaluate education and training needs for patients and family members. It also allows for tracking of signs and symptoms, cultures, and outcomes including unscheduled hospitalizations and secondary infection development.
It is the goal of Select Data to frequently offer tools for home health leaders and clinicians. You should expect to see clinical and operational tools geared toward assisting to identify areas of preventive practice and opportunities for training and education as well .
Expect future tools to focus on Cardiac Status, Dementia, Depression, as well in addition to business and QI tools.
Infection Control Tool (Excel)
Infection Control Tool (PDF)
PT/INR Evaluation Tool
PT/INR is a commonly used evaluation Lab test…
The Prothrombin Time (PT) evaluates the ability of the blood to clot properly. It is used to evaluate coagulation factors and bleeding likelihood of patients on anticoagulant therapy. This therapy is used to inhibit blood clots of patients who have had inappropriate clotting usually after a heart attack or after a deep vein thrombosis (DVT). The anticoagulant drugs must be monitored carefully so as to have a healthy balance between preventing a clot and causing excessive bleeding. The International Normalized Ration (INR) is used to monitor the effectiveness of the anticoagulant drugs.
Here is a handy tool to assist clinicians in monitoring not only the physician’s order but the follow up after the results are received.
The Face-to-Face Encounter and the Final CY 2011 Rule
There has been much discussion re the Face to Face Encounter required by the Affordable Care Act and a part of the CY 2011 Final Rule. (See page 296 of the Final Rule) What exactly is required?
The new regulation requires a patient to have been seen by the certifying physician within 90 days prior to the Start of Care (SOC). If that is not achieved, the patient must be seen within 30 days of admission to the home health agency.
The physician is required to document on the certification how the clinical findings of the encounter support eligibility requirements as well as primary focus of home care. (See pages 498-500 of the rule). The certifying physician must document that they or a specified Nurse Practitioner had the required face to face encounter (including use of telehealth which is subject to requirements in 1834 (m) of the Act).
The physician must document either on the certification form itself or as an addendum to it that the patient has a condition warranting home health involvement, that the patient is homebound, and has needs for skilled services. Per the letter sent to physicians from CMS dated 12/10/2011,
”The face to face encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. While the long standing requirement for physicians to order and certify the need for home health remains unchanged, this new requirement assures that the physician’s order is based on current knowledge of the patient’s condition”
- The new regulation effects Starts of Care initiated on or after January 1, 2011.
The final Rule states that agencies may not use “standardized encounter language” on the face to face encounter form that the physician must sign. A “template” may be used that allows physicians to describe the patient’s condition and primary reason for the encounter and referral to home health.
As a service to our clients and other agency leaders, Select Data has prepared a sample Face to Face Encounter Form for your use. You will note that it meets the requirements of:
- Specifying the individual completing the face to face encounterSpecifying the date of the encounter
- Specifying the primary medical reason/diagnosis/condition for the encounter
- Specifying additional clinical findings that support home health medical necessity
- Specifying the patient meets the CMS requirements of Chapter 7 Medicare Benefits Manual for homebound status
- Specifying findings of the encounter support the skilled services for home health; SN, PT, S/LP
- Signature and Date of the Physician
Please note the MLN website will have a special edition article which may be found at http://www.cms.gov/MLNGenInfo
Documentation Face to Face Encounter
Health Care Exempt from the Red Flags Rule
The Senate passed bill (S. 3987) on November 30, 2010 that would exempt health care providers from the Red Flags Rule mandated by the Federal Trade Commission (FTC). On December 7, 2010 the House of Representatives approved the bill and it has been sent to the President for signature.
Because of the growing threat of Identity theft, the FTC wanted health care providers included in the rule. The FTC has been quoted in stating that over 5% of identity theft victims have experienced medical identity theft.
The Red Flags Rule was to go into effect in health care June 1, 2010 but was delayed because the American Bar Association as well as the National Association for Home Care and Hospice (NAHC) sued the FTC. These organizations believed the intent of the rule was good but it would have caused significant financial burdens to be incurred as a result of the rule. Health care organizations do not have the same risk of identity theft as financial accounts from other industries might incur.
According to members of Congress, the Rule does not require any specific procedure to be used for Identity Theft protection. Agencies with higher risk should have more robust measures to protect sensitive information. The new Rule does clarify which business must comply with the Rule. The bill, expected to be signed by President Obama, would exempt health care providers.
Update on HHABN: New Form Available
The Revised Home Health Advance Beneficiary Notice (HHABN) is mandated to be implemented April 1, 2011. However, CMS has made Form CMS-R-296 available for use immediately.
The regulation as to application remains the same. HHABN notices MUST be issued whenever home health coverage is reduced or discontinued (with limited exception). The notices are issued to beneficiaries receiving the home health benefit for notification of potential financial liability and/or plan of care changes.
The new form has had minor changes. It continues to include an interchangeable Option Box with flexibility to insert Option Box 1, 2, or 3 on the form that is given to the beneficiary. The Option Box is unchanged with the current form dated 8/31/2009.
NOTE: For indepth information regarding the HHABN process, see Chapter 30, 40.3.5 of the Medicare Claims Processing Manual.
Form Triggering Events
There were no changes as to triggering events. The form must be delivered to the beneficiary upon the following:
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- Initiation – “When a HHA expects that Medicare will not cover any planned items and/or services from the start of the course of treatment given over a spell of illness, OR before the delivery of one-time items or services that Medicare is not expected to cover.”
- Reduction – “When a HHA reduces or stops some items and/or services during a spell of illness, while continuing others, including when one home health discipline ends but others continue.”
- Termination – “When a HHA ends delivery of all Medicare-covered care, but expects to continue delivering noncovered care.” Source: CMS HHABN Form Instruction OMB 0938-0781
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- Header
- Body
- Option Boxes
- Signature/Date Section
On the CMS website, an agency will find a “Sample” HHABN Form with instructions as well as three “agency ready” samples. Each sample form has Option Box text for each choice; Option Box 1, or 2, or 3.
Remember, an agency may customize the header section using their logo, name, and billing address.
For a complete list of instructions for use as well as the exact changes, go to www.cms.gov/BNJ/03_HHABN.asp
NOTE: If the termination involves the end of all Medicare covered care and no further care is to be delivered, the only notice necessary, per CMS, would be an Expedited Determination Notice (CMS-10123).
HHABN Sections
The HHABN will continue to be a one-page notice: