Face To Face Encounters CY2011 Clinical Compliance

CMS was mandated by the Affordable Care Act to provide this encounter. You will be able to look on page 296 on the Final Rule to read the depth of it. But, essentially what CMS is stating is that the physician must see the patient within 90 days prior to the admission in a home health agency.  And that means that also, in seeing that patient for that face-to-face encounter, that diagnosis or that reason for seeing that patient must be directly related to the home health referral.  Now, if they don’t see them within 90 days prior to they must see them within 30 days after admission.

As of December 10, 2010 CMS is sending out a notice to the physician regarding this face-to-face encounter information.  So the home health agencies are going to have to do a lot of education with physicians.  It also requires then, that the physician provide this attestation that they have completed this face-to-face encounter, and it has to be attached to/or a part of the POC.

At Select Data we’ve created a documentation of the face-to-face encounter tool click here to download a copy of this form:  http://www.selectdata.com/wp-content/uploads/2010/12/DocumentationFacetoFaceEncounter.pdf

Summary

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

1. All learning is physiological
2. The brain/mind is social
3. The search for meaning is innate
4. The search for meaning occurs through patterning
5. Emotions are critical to patterning
6. The brain/mind processes parts and wholes simultaneously
7. Learning involves both focused attention and peripheral perception
8. Learning always involves conscious and unconscious processes
9. There are at least two approaches to memory

10.  Learning is developmental

11.  Complex learning is enhanced by challenge and inhibited by threat associated with helplessness

12.  Each brain is uniquely organized

(Caine, Caine, McClintic, and Klimek, 2009 and Caine and Caine, 1994)

The principles assist us, as clinicians, leaders, managers, to understand that there are several different processes involved. Yet, we all tend to print up some teaching materials and have the nurses leave them with the patient “for reinforcement”. Many people believe, “If I told you, you have had education”.

The best selling education books, Tellin’ ain’t Trainin’ (Stolovitch, 2011) and Sit and Get Won’t Grow Dendrites (Tate, 2004) help us to better understand Brain-Compatible strategies. Some patients may learn well with the written word, while others are spatial and auditory learners.

Future Select Data articles will explore the constructs further but here is one sample activity.

If a patient treatment has changed or is being compared or contrasted, consider using a Venn Diagram. Draw two circles that have an overlapping center like below:

Information that is overlapping in the center is that information that is alike. The information outside that space identifies differences.

A spider chart with the new treatment or new topic in the center of a circle should be drawn. Then draw “spider-like” lines coming out of the circles. These can be goals to be achieved. As the patient articulates each goal they desire to achieve, linking it to the treatment or med in the center of the chart dramatically diagrams the importance of that treatment or medication.

A pie chart can be used to classify the careplan components. Breakdowns can make the plan seem more manageable. Each component or “piece” of the pie can appear to be managed at a setting, much like a tasty lemon pie.

We will look at this topic with more depth in the future. There is a PowerPoint Presentation on the topic of Learning and Brain Compatibility that is based on the Twelve Adult Learning Principles. This presentation was presented at two state association conferences and it could be shared with clinicians.

Having trouble downloading Learning and Brain Compatibility PowerPoint?

right click on the link > Then choose “Save Target As” > “Save”

]]> http://www.selectdata.com/adult-learning-principles-influencing-patient-outcomes-through-education/feed 0 http://www.selectdata.com/educational-videos-m1010-oasis-assessment http://www.selectdata.com/educational-videos-m1010-oasis-assessment#comments Mon, 11 Jul 2011 21:03:10 +0000 admin http://www.selectdata.com/?p=1924

Coding Compliance Completing The M1010 OASIS Assessment

If a patient was discharged from an inpatient facility in the past 14 days, then: M1010 needs to be completed.  If applicable then M1012 and M1016 needs to be completed.  Also please note that M1010 and M1016 are only to be used for diagnoses codes, and M1012 are only for procedure codes.

Most importantly, OASIS Guidelines state that “V” and “E” codes are not to be used in section M1010 and M1016.  Some examples of common V code wordings are:

• Aftercare
• Attention to
• History of
• Status of
• Fitting and adjustment of
• Long term use of a drug
• Other physical therapy
• Therapeutic drug monitoring
• Encounter for suture removal

If there are orders and goals related to these v codes please note they must be used in the correct section in M1020 and M1022 only.
It is important to document why a surgery or procedure was performed.  Many times we don’t have a history and physical or an operative report.

Was there a fracture, osteoarthritis, or neoplasm?

It is imperative to know why the according procedure was performed as it will impact the coding process.

This will help to expedite your coding process and ensure that you are using the most correct codes possible.

Presently, organizations are reviewing their privacy and security programs. How compliant is your Compliance and HIPAA programs? Perhaps you should conduct a gap analysis.

Getting started

To conduct a review and analysis of your agency’s compliance program you must know if your program covers the required elements:

• Complete written policies and procedures
• Designation of a Corporate Compliance Officer
• A training and education program regarding confidentiality, commitment to preventing fraud and abuse, and other elements of compliance
• Communication lines to the Corporate Compliance Officer
• Identification of compliance risk areas and a plan to mitigate risk
• Responding to non-compliance issues
• Policy of non-intimidation and non-retaliation against employees who identify non- compliance
• Disciplinary policies regarding non-compliant behavior

Consider the re-signing of the organization privacy policies annually by employees. This act can become a reminder of the importance of privacy and confidentiality in the organization. Identify who will conduct regular internal audits. Conduct this present review and analysis as if it were a surveyor visit, only this time, you get to be the surveyor.

Audit the HIPAA Program

As part of the compliance audit process, be certain to evaluate the HIPAA program. Are there plan objectives? Is an audit and monitoring system in place? Who has the responsibility for completion?  Identify the audit checklist. Is it inclusive? Is there a documentation process to record findings?

Are there annual goals to improve on privacy and security in the organization? How are audit findings reviewed? How does follow up occur?

The Audit

The following checklist should be considered a guideline (not necessarily all inclusive) and would require agency individual application.

• Is the Compliance plan, particularly the HIPAA portion, in compliance with the HIPAA Security Rule? Has an assessment been conducted regarding environmental/operational impact on PHI?
• Can the organization identify how it protects access to information? Is there a policy re access to PHI and “need to know?”
• Can patients obtain their information in a timely manner? Can information be provided in electronic format, as required by HITECH. Has a security risk analysis been conducted?
• Have security measures been implemented to reduce the risk? What are those measures?
• Have the Compliance, Privacy, and Security risk analysis available for an OCR audit or questions from an accrediting surveyor.
• At the very least, for privacy, look at the following:
• Can patients/guests view PHI? See computer screens? Is there any place on the premises that PHI is readily available?
• Is PHI posted on wall boards where those who have “no need to know” have access to the info?
• Is PHI left on desks? Are computer screens left on when the user steps away?
• Are recycling bins used? Is there a BAA with that recycling vendor?
• Are all BAAs in place with all vendors and in compliance with HIPAA HITECH?
• Communication:
• Is PHI faxed? Is there a confidentiality/disclosure statement on each fax coversheet?
• Does the online system require level logins?
• Are screen savers activated in a short period of time?
• Are emails used with PHI? Are the emails encrypted?
• Are phone calls used to give and receive PHI? How is the individuals receiving or giving info identified and confirmed?
• Responsibility:
• Can each employee identify when PHI enters their area of responsibility?
• Who handles PHI? Where is it stored? What is the back up process? What is the length of storage? Is it secure? How do you know it is secure?
• Have all employees been trained in privacy? Has security at the specific employee level been conducted? Is compliance training mandatory? Is it conducted annually?
• Is there a protocol for new employees? Is there a protocol regarding confidentiality upon employee departure?
• Are BAAs in place holding contractors accountable for PHI protection?  Have you seen their policies, procedures, and processes?
• Reports:
• Are reports created that have confidential information? Are they circulated to only those with “need to know” rights?
• Have the reports been reviewed to reduce the amount of sensitive information, if possible? Could de-identified information be substituted?
• Is transmission of report information secure?
• Security:
• Is there a written policy to protect PHI? Is there policies re computer screens in view with PHI? Are there policies re passwords?
• Are there policies re storage of data and how backup tapes and storage devices are accounted for and monitored?
• Has every station been evaluated as to protection of PHI and view and accessibility to information by those who do not have clearance to that station.
• Technical Security:
• Does the technical team periodically verify the technological security is in place and working appropriately? Can the technical team identify if an unauthorized user has accessed PHI? What safeguards are in place to protect against unauthorized access?
• Is technology in place to verify identity of users?
• Are passwords and IDs routinely changed per a schedule?

OCR Investigations and Review:

If you have a breach that triggers an investigation by OCR, be certain to promptly respond as to what happened, how it happened, what was done to mitigate outcomes, and what has been implemented to prevent a future occurrence.  Be certain to identify the fact you have a full Compliance Program in place. Identify that all employees have routine education re Compliance and HIPAA.

If documents are requested, your counsel may request confidentiality for those documents being sent to OCR. Create and maintain a log of events, complete with dates, times, and people involved throughout the entire investigation process. Save all electronic documents. Keep statements by all employees involved in the incident and the investigation. Obtain counsel’s advice as to phone conversations with OCR as written correspondence maintains an investigation trail.

Focus on internal compliance. If there is a HIPAA breach, there must be remediation/education regarding the process and the prevention of a reoccurrence.

Summary:

• Keep your plan objectives current.
• Identify who is responsible for the audits and establish times and how findings will be transmitted.
• Have corrective action plans in place.
• Include documentation of audits, results, and remediation/corrective action/education
• Report findings to the BOD, leadership, and counsel.
• If there is an OCR audit/investigation have a team established to quickly respond, pull data, analyze, and report.
• Have an ongoing risk analysis performed as specified by policy. Be certain the risk analysis encompasses the technical requirements of the Security Rule.
• Be certain the Risk Analysis is well documented. Be certain the plan for mitigation of any adverse findings is in place.

Like the clinical documentation rule, “if it wasn’t documented you did not do it,” so it is true here also. Document each step of the plan. If ever there is an audit, the fact a full compliance plan is in place in your agency including a HIPAA Privacy and Security review, can speak volumes about you and your organization.

Pathophysiology

Heart failure may occur when damage is done to the heart preventing it from adequately pumping blood to tissues to meet required metabolic needs. Because the circulatory system carries oxygen and necessary nutrients, a decreased blood flow limits needed tissue nourishment, resulting in compensation by the body as it seeks balance or homeostasis. The body is forced to stimulate the sympathetic nervous system to increase both the heart rate and blood pressure to meet oxygen and nutrient requirements. The kidneys will assist, by a process of  vasoconstriction, within the tubules, to increase blood pressure and secondarily retaining and reabsorbing sodium to increase vascular pressure that will aid in also raising blood pressure. In the short term, this is effective. However, long term effects include cardiac decompensation and increased symptoms of heart failure.

Symptoms frequently seen during exacerbations

Per HHQI, Best-Practice Disease Management: Heart Failure Intervention Package, expect to see

• Shortness of breath
• Decreased urination
• Chest pain or heaviness
• Increased weakness or fatigue
• Edema of the feet, ankles, hands, abdomen, or sacrum (anasaca)
• Increase in weight of 2-3 pounds in 24 hours or 3 pounds in one week
• Dry hacking cough or cough producing a white foamy sputum
• Orthopnea (the number of pillows needed propped up to breath comfortably)
• Paroxysmal nocturnal dyspnea (feeling of smothering or fullness in the chest when lying down and resolves when standing up).

An effective in-home prevention and treatment plan helps the patient control symptoms. It also helps control the costs associated with heart failure by reducing the need for emergent and/or inpatient care. Since heart failure patients are among those most often seen in emergent and inpatient settings, a home health clinical specialty heart failure program is necessary for cardiac patients to reduce this incidence. This care is a focus of CMS. New Survey Protocols, effective May 1, 2011, focus on data gathering and outcomes seen, as opposed to the focus on structure and process orientation of past surveys. Care planning and delivery with resulting outcomes of all patients will be the focus, but because heart failure is of growing incidence, expect scrutiny.

As the OASIS process measure begins to produce data, one can expect to see the evaluation and adjustment of processes brought to the forefront. Agencies must consider a specialized episode  and disease management plan for heart failure patients under care. This program will assist the agency reach its goals clinically, operationally, and financially.

The CMS OASIS data items were created to measure processes of care in several areas to reflect Institute of Medicine (IOM) goals and Medicare Payment Advisory Commission (MPAC) recommendations. It was felt there is a need to focus on high-risk, high-volume, chronic conditions seen in the home health setting and although CMS indicates that the integrated OASIS-C process items are optional practices, it is believed by industry specialists and content experts that identified best practices are critical to providing efficient quality home health care with expected/predictable outcomes.

Evidence-based  best practices

The rationale behind process data elements is to encourage agencies to incorporate evidence-based practices (EBP) into processes. One definition of EBP is to use the best scientific evidence available as a tool to guide clinical decision-making for the purpose of attaining the best outcomes.

Research supports that a combination of proper acute care discharge planning and post discharge care for patients with heart failure can significantly reduce hospital readmission rates, improve quality of life, and reduce cost of care. Heart failure evidence-based standards of care per the American College of Cardiology/American Heart Association (ACC/AHA) include:

• Assessment for fluid retention via monitoring weight and abdominal girth.
• Assessment of activity level, perceived dyspnea, fatigue, reduced exercise tolerance, sleep patterns, and patient’s activity that triggers dyspnea.
• BP standing/sitting, heart rate (HR), respiratory rate (RR), jugular venous distention (JVD) every visit.
• Assess edema and instruct the patient as to obtaining daily weight and complete a patient assessment of abdominal and peripheral swelling, focusing on feet/ankles, hands, sacrum, scrotal area, and abdomen.
• Complete auscultation of heart and lung sounds; identify S3 or S4. Assess for new or recurrent dysrhythmias or murmurs. Per HHQI “changes in heart rhythm can lead to poor cardiac output and worsening heart failure. Note: Extra sounds can be a warning of impending heart failure exacerbation.”
• Assess lung sounds to identify any changes or note wheezes, crackles, rhonchi, or diminished breath sounds.
• The physician may well monitor serum electrolytes/renal function every 6 months.
• Assess appetite. Expect the physician to order a low-fat, low-sodium diet; fluid restriction. When assessing appetite, look for signs of abdominal fluid retention such as feelings of abdominal fullness and early satiety. Refer to girth baseline and successive measurements.
• Assess for orthopnea and paroxysmal nocturnal dyspnea. Verify number of pillows used when lying down. Both of these symptoms are usually intermediate signs of fluid retention and per HHQI, “intervention at this point could still prevent re-hospitalization.”
• A thoracic impendence reading (ZO) may be ordered. Fluid status changes can signify need for intervention and possibly prevent a hospitalization.
• Assess urinary output. Decreased output could signal impending signs of renal failure or heart failure decompensation, as the body attempts to raise blood pressure.
• Assess diabetes control, if applicable.
• Assess psychosocial coping and note symptoms of depression. Assess family and support systems. Depression intervention may be necessary to maintain optimum self care-management.
• If ordered, encourage regular walks progressing to 1 hour per day 3-5 days per week..
• Smoking: Discourage first-hand and second-hand smoke.

Agency Administrators

Administrators who are looking to establish a cardiac program in their agency should review the HHQI “Best Practice Disease Management: Heart Failure.” This Nurse Track is a Best-Practice Disease Management intervention package that supports the implementation, education, and application of current assessment and symptom management modalities with clinical processes to decrease active symptoms in heart failure patients. It discusses providing a structured plan for care, and supports EBP.  The package describes nursing actions that support an effective disease management program.

The administrator should also include an assessment of current standards of care in relation to the number of visits incurred as well as type and depth of  education provided to patients, along with early intervention for symptoms of heart failure. Once the assessment plan is completed, a review of nursing education gaps assessed, agency-wide education must occur to ensure that all clinicians are familiar with best-practice standards and provide opportunity for feedback. After that education is provided and the standards are implemented, outcomes should be analyzed, and ongoing auditing for compliance should be established to ensure the best practice standards are maintained.

Guidelines in Best-Practices for Administrators

There are many programs available regarding best-practices for care of patients with heart failure. The HHQi site offers RNs a free 2.0 Continuing Nursing Education units after completion of the 115 minute five activities for the Heart Failure Track. In addition, there are tools and podcasts to aid in reducing hospitalizations as well as a Decision Support Tool: Heart Failure

Once the program is underway, data analysis becomes an important practice allowing the administrator to review statistics and trends within the agency-specific patient populations. For the administrator planning to survive present and anticipated future changes in regulation, care delivery, and reimbursement models effective decision-support software providing data aggregation, benchmarking, and analysis opportunities for operational management will be essential.

Administrators should monitor specific patient populations for trending and analysis that include:

• Hospitalization rates by diagnoses
• Disciplines utilized within an episode
• Visit patterns and scheduling
• Number of days from SOC before therapy began care
• Average number or recertifications
• Therapy utilization for energy conservation training
• Changes in patient education between SOC and recertification episode

In addition to monitoring heart failure outcomes through OASIS-C data, reduced hospitalization rates, compliance with the structured heart failure disease management program the agency should find ways to motivate personnel to continue use of the enhanced heart failure education. Administrators should be certain a specific skilled staff competency review regarding heart failure symptoms is administered regularly.

Best practices disease management programs can be very successful as seen in Dominion Care Home Health agency in San Antonio, TX. Their acute care hospitalization (ACH) rate declined from 41% to 28% after initiating such a program. With pay for performance in our future, newly instituted Survey Protocols, and higher expectations for improved patient outcomes, a disease management program targeting heart failure is a must.

Sources:

www.homehealthquality.org

HHQI Best Practice Intervention Practice, 8SOW-PA-HHQ07 467 App, 1/2008

www.qualitynet.org

http://mhcc.maryland.gov/consumerinfo/hospitalguide/hospital_leaders/best_practices/hf..h

www.chronicconditions.org/ClearingHouse/cat/Heart%20Failure,61.aspx

Heart and Ling Sounds by 3M

http://solutions.3M.com/wps/portal/3M/en_US/Littmann/stethoscope/education/heart-lung-sounds

Decision Support Tool: Heart Failure Publication # 8SOW-PA-HH05.187

For more detailed information, visit http://www.cms.gov/Surveycertificationgeninfo/downloads/SCLetter11_11.pdf to read the advanced copy.

Under revised survey protocols, agencies will be evaluated on a set of 34 standards, known as Level 1 standards. If the surveyor finds a deficiency on any one of the new highest priority standards, a partial extended survey will be conducted.

During that survey, the agency will be evaluated on 27 Level 2 standards. Both sets of standards fall under the nine conditions of participation. Surveyors must conduct extended surveys of all CoPs when any of the more serious condition level deficiencies are cited. Part 1 of this series outlined each CoP and where the G Tag fell; Level 1 or Level 2.

Many agency leaders are stating that it seems the new survey process has more detailed guidance to reduce surveyor inconsistency.

The survey tasks have been clearly delineated by CMS:

• Task 1- Pre-Survey Preparation
• Task 2- Entrance Interview
• Task 3- Information Gathering
• Task 4- Information Analysis
• Task 5- Exit Conference
• Task 6-Formation of the Statement of Deficiencies

Pre-Survey Preparation

Surveyors will prepare for surveys, more indepthly, using OASIS data, previous survey findings, and complaints filed.  Available OASIS reports can be generated for specific time periods, as requested, from the OASIS Coordinator’s office. These reports include case-mix, potentially avoidable events, risk adjusted outcomes based quality improvement (OBQI) or process measure reports.

OBQM Potentially Avoidable Events Report

Know that before coming to the home health agency, the surveyor will have reviewed the most recent quarter of OASIS data to identify patients with emergent care as a result of a fall at home or emergent care for wound infection or deteriorating wound status. This is a Tier 1 event. There are six Tier 2 Potentially Avoidable Events for consideration. To reach the threshold there must be patients who experienced the event and/or the agency to be surveyed must have a current incidence rate equal to or greater than twice the reference rate (Appendix B p.12)

OBQI Outcome Report

Surveyors will also review the agency’s Risk-adjusted Outcomes Report prior to survey. CMS instructs surveyors : “During the onsite survey, select patient records and home visits that focus on the outcomes identified on the OBQI report meeting the individual investigation thresholds” (Appendix B. p12).  If none of the ten listed outcomes trigger the selection criteria, another outcome should be selected from the OBQI report (that meets the selection criteria).

Patient/Agency Characteristics Report

As part of the pre survey process, the surveyor will look at this report for the same timeframe as the OBQI Outcome Report and focus on acute conditions and home care diagnoses that are statistically significant or are equal to or greater than 15% points higher than the reference rate. The surveyor is to choose up to three diagnoses or conditions that meet the criteria and look at corresponding patient records.

Error Summary Report by HHA

Surveyors will be looking for several inconsistencies and errors, such as  inconsistent M0090 date and incorrect record sequence. The latter error could trigger further record reviews if the HHA’s percent of assessments with this error in or above 10%.

What Can an Agency Do on an Ongoing Basis?

Routinely, agencies should be reviewing the online OASIS reports and identifying areas for improvement. They should show interventions planned and implementation of the plan. The agency should also reflect follow up to implementation. This practice establishes a commitment to Quality Improvement and seeking proactive interventions for areas such as recurring hospital admissions.

Part 3: Entrance Interview

CMS remains detailed as to activities that are to be included in the entrance interview.  This interview sets the tone for the survey process identifying expectations. We will explore those in the next article.

Every home health agency wants their deserved reimbursement for the care delivered to their patient and just as importantly, they want to retain that revenue. A good start toward achieving that goal is having coding team expertise.

According to one source, the average loss on a miscoded record is hovering around $1200+. The reasons for the errors vary; experience of the coding team, training level, maintaining competency and adherence to coding guidelines and conventions with the hundreds of changes that occur annually and not to mention the over 100,000 changes coming with ICD-10. A coding team needs to be dedicated to just that: coding, not other distracting duties. The team needs coders and clinicians so the full prospective of the patient portrait is accurately presented and the proper codes are compliantly assigned.

With tighter reimbursement, outcomes affecting future reimbursement, and coding driving certain audit alerts, coding is the area that requires emphasis.

Select Data has written a white paper on this subject. Looking at industry complexity and how coding importance came to the forefront to identifying the relationship of case-mix profile and case-mix adjustment models to coding. In addition, understanding the components of the HIPPS Codes as well as how supplies must link to diagnostic codes is included.

Success in this industry usually means the home health leaders have a good understanding of why the change in CMS focus as well as what is expected from that focus. Included in this white paper, you will also find the documentation requirements for coding in general as well as examples of the therapy risk areas. Documentation must be objective and specific. Just what does that mean? Clear examples are presented.

Being alert for “alerts.” Do you know what MAC alert 5023T means? You need this kind of information from your coding team.

The value of compliant coding is proper payment and peace of mind. This is not a trite statement. It is a desire of agency leaders who are working diligently to comply with quality parameters, best practices, and regulatory statutes and law.

To read the full white paper, please go to: Coding Whitepaper PDF

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 encounter

·            Specifying 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

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)