Billing App Update: Version 2.012



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Billing App Update: Presented by M. Aaron Little, CPA BKD, LLP Springfield, MO mlittle@bkd.com Today s Agenda 2012 prospective payment system (PPS) rates Timely filing Healthcare Common Procedure Coding System (HCPCS) codes Therapy reassessments Physician face-to-face (FTF) encounters 2 1

2012 PPS Rates 3 2012 PPS Rates 4 2

2012 PPS Rates Payment rate schedules available for all CBAS Send email to Lacee Richmond at lrichmond@bkd.com Include following information Your name Your email address Your agency s name, city & state Your CBSA codes 5 Timely Filing Timely Filing 6 3

Timely Filing One year timely filing period Claims for services provided on or after January 1, 2010, must be successfully billed no later than 12 months after the through date of claim Review aging reports monthly Age by service date Prioritize all at risk claims Unpaid claims from first quarter 2011 past timely Know software system aging report capabilities 7 Timely Filing Review aging reports in detail if possible each month to identify Medicare balances approaching one year old Ensure adequate & effective billing personnel time is devoted each month to billing follow-up Rule of 20%/80% 8 4

HCPCS Timely Filing Codes 9 HCPCS Codes All codes begin with G Codes expanded from six billable codes to 14 billable codes New codes apply only to home health Does not apply to hospice yet Only one code used for each visit billed Applicable code billed should describe how most of time during visit was spent See Attachments A and B 10 5

HCPCS Codes Skilled nursing visits G0154 G0162 Management & evaluation of plan of care G0163 Observation & assessment of patient condition G0164 Training &/or education of patient or family member 11 HCPCS Codes 12 6

HCPCS Codes 13 HCPCS Codes 14 7

HCPCS Codes Physical therapy (PT) visits G0151 Qualified physical therapist G0157 Qualified physical therapist assistant G0159 Qualified physical therapist in establishment or delivery of safe & effective therapy maintenance program 15 HCPCS Codes Occupational therapy (OT) visits G0152 Qualified occupational therapist G0158 Qualified occupational therapist assistant G0160 Qualified occupational therapist in establishment or delivery of safe & effective therapy maintenance program 16 8

HCPCS Codes Speech therapy (ST) visits G0153 Qualified speech-language pathologist G0161 Qualified speech-language pathologist in establishment or delivery of safe & effective therapy maintenance program 17 2010 2011/2012 HCPCS HCPCS All Visit Categories Code Code Skilled nursing visit by a RN or LPN G0154 G0154 Skilled nursing visit by a RN for management & evaluation Not applicable G0162 Skilled nursing visit by a RN or LPN for observation & assessment Not applicable G0163 Skilled nursing visit by a RN or LPN for education & training Not applicable G0164 Physical therapy visit performed by a physical therapist G0151 G0151 Physical therapy visit performed by an assistant Not applicable G0157 Physical therapy maintenance program visit Not applicable G0159 Occupational therapy visit performed by an occupational therapist G0152 G0152 Occupational therapy visit performed by an assistant Not applicable G0158 Occupational therapy maintenance program visit Not applicable G0160 Speech therapy visit G0153 G0153 Speech therapy maintenance program visit Not applicable G0161 Medical social worker visit G0155 G0155 Home health aide visit G0156 G0156 18 9

HCPCS Codes Claims beginning to be reviewed by Medicare contractors for coding accuracy 2011 HCPCS code data utilized by CMS in analyzing utilization as step in revising 2012 casemix weight & payment CMS analysis will continue to examine the trends in the G-code reporting going forward and we [CMS] plan to use the information in rate setting. 19 HCPCS Codes Critical to evaluate current service codes to confirm codes are being used consistently & correctly Review code mapping in billing software to ensure codes correctly map to claims Ensure customary visit charges are applied correctly & consistently 20 10

HCPCS Codes Example 21 Therapy Reassessments 22 11

Therapy Reassessments 2012 PPS payment for therapy still dependent on visit utilization Payment more evenly distributed between utilization increments Payment redistributed from late episodes to early episodes 23 Therapy Reassessments Therapy Visits 0 to 5 visits 2012 (2011) Oklahoma City PPS Rates Early Episodes Late Episodes Payment Change Cumulative Payment Change Cumulative 6 visits $315 ($537) $315 ($537) $398 ($700) $398 ($700) 7 to 9 visits $316 ($419) $631 ($956) $398 ($405) $796 ($1,105) 10 visits $315 ($429) $946 ($1,385) $398 ($443) $1,194 ($1,548) 11 to 13 visits $316 ($353) $1,262 ($1,738) $398 ($350) $1,592 ($1,898) 14 to 15 visits $315 ($323) $1,577 ($2,061) $398 ($302) $1,990 ($2,200) 16 to 17 visits $414 ($312) $1,991 ($2,373) $375 ($232) $2,365 ($2,432) 18 to 19 visits $414 ($275) $2,405 ($2,648) $375 ($313) $2,740 ($2,745) 20 or more visits $414 ($1,291) $2,819 ($3,939) $375 ($1,050) $3,115 ($3,795) 24 12

Therapy Reassessments Reassessment requirements Must be performed by qualified therapists Cannot be performed by assistants Must occur by each discipline involved in care of patient At least once every 30 days Prior to 14 th & 20 th covered visits Must functionally reassess, compare the resultant measurement to prior assessment measurements, & determine effectiveness of therapy 25 Therapy Reassessments Documentation requirements Must document measurement results of functional reassessment compared to prior measurements Must document therapist s determination of effectiveness of therapy Must document why therapy should be continued or, if applicable, discontinued 26 13

Therapy Reassessments Single therapy discipline episodes Reassessments must occur at least every 30 days 30-day period may span episodes Reassessments must also occur on exactly 13 th & 19 th covered visits, unless Patient lives in rural area, or Documented circumstances beyond control of therapist prevent reassessment from occurring on exactly 13 th & 19 th visit Must occur on covered visit 11, 12, or 13, & Must occur on covered visit 17, 18, or 19 27 Therapy Reassessments Multiple discipline therapy episodes 28 Reassessments must occur at least every 30 days 30-day period may span episodes Reassessments must also occur by each discipline close to but no later than 13 th & 19 th covered visits Based on cumulative total of all visits by all therapy disciplines Exception If no visit scheduled between covered visits 14 & 19 by one discipline, & Last visit by that discipline was a reassessment, Then no reassessment required by that discipline prior to covered visit 20 14

Therapy Reassessments Example PT & OT providing visits PT reassessment occurs on visit 12 OT reassessment occurs on visit 13 Only PT visits ordered between covered visits 14 & 19 Only PT reassessment required prior to covered visit 20 29 Therapy Reassessments Noncompliant visits Any late reassessment(s) Late based on 13 th & 19 th covered visit requirement, or Late based on 30-day requirement All therapy visits performed after visits 13 & 19 noncovered until first visit after required reassessment(s) performed by qualified therapist(s) 30 15

Therapy Reassessments Clarification from final 2012 PPS rule 30-day reassessment requirement can be delayed if due to physician order When warranted by sudden change in patient condition Must be supported by documentation Only covered visits included when counting 14 th & 19 th visits Noncovered therapy visits required to be billed on claim with charges coded as noncovered????? 31 Therapy Reassessments Published billing guidance from Cigna 32 16

33 34 17

35 36 18

37 38 19

39 40 20

41 Therapy Reassessments Ensure care coordination & communication between therapy disciplines & billing personnel Utilize schedule features &/or therapy tracking tools in operations software Evaluate software capabilities & internal processes for billing noncovered charges Monitor Cigna ability to correctly process claims with noncovered visits Verify previously billed claims with noncovered charges were accurate & paid correctly 42 21

Home Health Physician FTF Encounters 43 Payers Currently applies only to Medicare Traditional Medicare Medicare secondary payer Some Medicare Advantage plans may choose to follow Medicare requirements Highmark of Western Pennsylvania, etc. 44 22

Payers Separate requirements proposed by CMS for state Medicaid programs Proposed rules published in Federal Register dated July 12, 2011 Very similar to Medicare requirements No effective date proposed yet Some states already adopted Medicaid requirement Ohio Not Missouri yet 45 Encounter Timing Required on SOC episodes only Not required for recertification episodes Must occur within 90 days prior to or 30 days after SOC 46 23

Billing Timing Receipt of qualifying FTF encounter documentation must correspond with timing of billing RAPs can (& should) be billed while agency waits for receipt of documentation Final claims cannot be billed until after receipt of documentation 47 Patient Death If patient dies before FTF encounter occurs Episode billable if death occurs by day 30 If documentation substantiates to the satisfaction of the Medicare administrative contractor that the provider exercised a good faith effort to facilitate & coordinate the encounter, & If all other certification requirements are met Episode not billable if death occurs after day 30 48 24

Patient Discharge If patient discharged before day 30 & FTF encounter not yet performed Episode billable after encounter performed & documentation received 49 Timing Noncompliance If FTF encounter does not occur by day 30 Medicare benefit requirements not met Episode cannot be billed Does require corrective OASIS actions Does require corrective billing actions Decision must be made Discharge patient? Continue services? 50 25

Timing Noncompliance If agency chooses to discharge patient Must issue Home Health Advance Beneficiary Notice (HHABN) To notify patient due to lack of qualifying encounter Must use new HHABN effective April 1, 2011, Option Box 2 https://www.cms.gov/bni/03_hhabn.asp Cannot hold patient financially responsible for services received at time of discharge Change of care notice Discharge for administrative reasons May deliver in advance of actual discharge date to allow time to meet requirement 51 52 26

You have not had a face-toface visit with your physician within 30 days of your admission to this home health agency, as is required by Medicare. 53 SOC OASIS(s) deleted OASIS transmitted RAP canceled RAP billed RAP paid No FTF encounter by day 31 HHABN issued 54Patient discharged RAP payment recouped No services billable to Medicare or to patient No Medicare record that services were provided 27

Timing Noncompliance If agency chooses to continue services New SOC date required Requires new OASIS assessment Requires new RAP billing All services prior to new SOC date noncovered & cannnot be billed/paid 55 Timing Noncompliance Additional CMS clarification pending on what SOC date is allowed once the encounter has occurred, the agency would delete the original OASIS submission (Medicare was not the payer when that OASIS was done), establish a new start of care date, and complete a new OASIS. CMS FAQ Answer ID 10666 where a face-to-face encounter did not occur within the 90 days prior to the start of care or within 30 days after the start of care, a provider may complete another OASIS with a start of care date equal to the date when all Medicare eligibility is met. Federal Register dated November 4, 2012 56 28

SOC New OASIS transmitted OASIS transmitted RAP canceled RAP billed RAP payment recouped RAP paid FTF encounter occurs after day 30 New SOC New RAP billed New RAP paid Final claim billed Original 57 OASIS(s) deleted Final claim paid Documentation Must be separate & distinctly identifiable section of certification or addendum Must be clearly titled, signed & dated by qualified certifying physician Must include qualifying FTF encounter date 58 29

Documentation Must include narrative clinical findings Composed by qualified certifying physician Reflect clinical condition of patient as seen during qualifying FTF encounter Explain how findings support Encounter was related to primary reason for home health Patient needs intermittent skilled nursing &/or therapy Patient is homebound 59 60 30

Documentation Narrative clinical findings Must be composed by qualified certifying physician Physician may compose after date of encounter using medical record entries from FTF encounter Physician may dictate to support personnel May not dictate to home health agency personnel Physician may utilize own electronic medical records prepared descriptive language Use of home health agency standardized language not permitted Physician may utilize support personnel to compile narrative 61 Documentation Support personnel Those that work with or for physician on regular basis & regularly perform documentation, take dictation from physician &/or extract support documentation from physician s medical records Can compile narrative by extracting information from physician s medical record entries documented during qualifying FTF encounter NPPs do not meet support personnel criteria Cannot compose home health qualifying encounter certification documentation even if NPP performed FTF encounter Must document & communicate clinical findings to qualified certifying physician 62 31

Documentation Other physicians Effective SOCs January 1, 2012, & thereafter Physician or NPP caring for patient during acute or postacute inpatient stay & performing FTF encounter can communicate findings to certifying physician who signs certification/addendum Only applies to patients receiving FTF encounter during acute or post-acute inpatient stay Certification language must be updated to document possibility of other physician 63 64 32

Documentation Attachments can satisfy narrative requirement May utilize copies of physician s documentation on orders, acute/post-acute discharge summaries, or other documentation if Reflects clinical condition of patient as seen during encounter & supports need for intermittent skilled nursing &/or therapy services & that patient is homebound Were drafted by physician or compiled by physician s support personnel Clearly signed & dated by qualified certifying physician Clearly attached as part of the certification/addendum 65 66 33

Physician FTF Encounters What are your agency s policies? Admission policies Admit patients if qualifying encounter has not yet occurred? Discharge policies Continue services if qualifying encounter does not occur? Discharge patients once qualifying encounter window of time has passed? Do billing personnel know policies? 67 Physician FTF Encounters What is your software vendor s capabilities of facilitating FTF encounter noncompliance? What is communication process relating to timing of FTF encounter compliance between clinical & billing personnel? Do billing personnel know how to handle FTF noncompliance situations? 68 34

Physician FTF Encounters Example SOC occurred April 1, 2011 RAP paid April 12, 2011 FTF encounter occurred May 5, 2011 Visits performed to date SN 04/01/11 SN 04/03/11 SN 04/05/11 SN 04/07/11 SN 04/09/11 SN 04/11/11 SN 04/15/11 SN 04/19/11 SN 04/24/11 SN 05/01/11 SN 05/07/11 OT 04/04/11 OT 04/16/11 OT 04/18/11 OT 04/21/11 69 04/01/11 original SOC Original OASIS transmitted Original RAP billed Original RAP paid FTF encounter occurs 05/05/11 New SOC established as of 04/05/11 Original 70 OASIS(s) deleted New SOC 04/05/11 OASIS transmitted Original RAP canceled Original payment recouped New 04/05/11 RAP billed New 04/05/11 RAP paid Final claim billed Final claim paid 35

Summary 71 Summary Avoid timely filing writeoffs Correctly report HCPCS codes Avoid noncovered visits & payment reductions due to therapy reassessments Successfully manage physician FTF encounter processes 72 36

Thank You! 73 37

Attachment A

Quick Reference Medicare Home Health Program Key Billable Healthcare Common Procedure Coding System (HCPCS) Codes Billable Revenue HCPCS Effective Code Code Date Description Skilled Nursing 0551, or 0550 G0154 01/01/11 Direct skilled nursing services of a licensed nurse (LPN or RN) in the home health or hospice setting, each 15 minutes Code billed if no other appropriate code describes primary purpose of visit 0551, or 0550 0551, or 0550 0551, or 0550 G0162 01/01/11 Skilled services by a RN in the delivery of management & evaluation of the plan of care ; each 15 minutes (the patient s underlying condition or complication requires an RN to ensure that essential non-skilled care achieve its purpose in the home health or hospice setting) Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Section 40.1.2.2 where underlying conditions or complications require that only a registered nurse can ensure that essential nonskilled care is achieving its purpose the complexity of the necessary unskilled services that are a necessary part of the medical treatment must require the involvement of skilled nursing personnel to promote the patient s recovery and medical safety in view of the patient s overall condition. G0163 01/01/11 Skilled services of a licensed nurse (LPN or RN) in the delivery of observation & assessment of the patient s condition, each 15 minutes (when the likelihood of change in the patient s condition requires skilled nursing personnel to identify and evaluate the patient s need for possible modification of treatment in the home health or hospice setting) Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Section 40.1.2.1 when the likelihood of change in a patient s condition requires skilled nursing personnel to identify and evaluate the patient s need for possible modification of treatment or initiation of additional medical procedures until the patient s treatment regimen is essentially stabilized. G0164 01/01/11 Skilled services of a licensed nurse, in the training &/or education of a patient or family member, in the home health or hospice setting, each 15 minutes Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Section 40.1.2.1 activities that require skilled nursing personnel to teach a patient, the patient s family, or caregivers how to manage the treatment regimen 1 of 3

Quick Reference Medicare Home Health Program Key Billable Healthcare Common Procedure Coding System (HCPCS) Codes Billable Revenue HCPCS Effective Code Code Date Description Physical Therapy 0421, or 0420 G0151 01/01/11 Services performed by a qualified physical therapist in the home health or hospice setting, each 15 minutes Code billed if no other appropriate code describes primary purpose of visit 0421, or 0420 0421, or 0420 G0157 01/01/11 Services performed by a qualified physical therapist assistant in the home health or hospice setting, each 15 minutes G0159 01/01/11 Services performed by a qualified physical therapist, in the home health setting, in the establishment or delivery of a safe and effective therapy maintenance program, each 15 minutes Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Sections: 40.2.1, 40.2.2.C, 40.2.2.D, 40.2.2.E skills of a therapist are needed to manage and periodically reevaluate the appropriateness of a maintenance program because of an identified danger to the patient specialized knowledge and judgment of a qualified physical therapist is required for the program to be safely carried out and the treatment of the physician to be achieved. Occupational Therapy 0431, or 0430 G0152 01/01/11 Services performed by a qualified occupational therapist in the home health or hospice setting, each 15 minutes Code billed if no other appropriate code describes primary purpose of visit 0431, or 0430 0431, or 0430 G0158 01/01/11 Services performed by a qualified occupational therapist assistant in the home health or hospice setting, each 15 minutes G0160 01/01/11 Services performed by a qualified occupational therapist, in the home health setting, in the establishment or delivery of a safe and effective therapy maintenance program, each 15 minutes Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Sections: 40.2.1 skills of a therapist are needed to manage and periodically reevaluate the appropriateness of a maintenance program because of an identified danger to the patient 2 of 3

Quick Reference Medicare Home Health Program Key Billable Healthcare Common Procedure Coding System (HCPCS) Codes Billable Revenue HCPCS Effective Code Code Date Description Speech Therapy 0431, or 0430 G0153 01/01/11 Services performed by a qualified speech-language pathologist in the home health or hospice setting, each 15 minutes Code billed if no other appropriate code describes primary purpose of visit 0431, or 0430 G0161 01/01/11 Services performed by a qualified speech-language pathologist, in the home health setting, in the establishment or delivery of a safe and effective therapy maintenance program, each 15 minutes Refer to CMS Medicare Benefit Policy Manual, Chapter 7 Home Health Services, Sections: 40.2.1 skills of a therapist are needed to manage and periodically reevaluate the appropriateness of a maintenance program because of an identified danger to the patient 3 of 3

Attachment B

NHIC, Corp. MEDICARE ADMINISTRATIVE CONTRACTOR JURISDICTION 14 A/B MAC Billing G-codes for Therapy and Skilled Nursing Services Summary Effective for episodes beginning on or after January 1, 2011, home health agencies are required to report additional, and more specific, data about therapy and nursing visits on home health episode claims. The requirements include: Revision of current descriptions for existing G-codes for physical therapists (G0151), occupational therapists (G0152), and speech-language pathologists (G0153) Two new G-codes added (G0157 and G0158) for the reporting of physical therapy and occupational therapy services provided by qualified therapy assistants Three new G-codes added (G0159, G0160 and G0161) for the reporting of the establishment or delivery of therapy maintenance programs by qualified therapists Revision of current definition for the existing G-code for skilled nursing services (G0154) HHAs required to use G0154 only for the reporting of direct skilled nursing care to the patient by a licensed nurse (licensed practical nurse or registered nurse) Three new G-codes added (G0162, G0163 and G0164) for skilled nursing care What You Need to Know to Bill Physical Therapy G0151 Services performed by a qualified physical therapist in the home health or hospice setting, each 15 minutes (new code description) G0157 Services performed by a qualified physical therapist assistant in the home health or hospice setting, each 15 minutes (new code description) G0159 Services performed by a qualified physical therapist, in the home health setting, in the establishment or delivery of a safe and effective physical therapy maintenance program, each 15 minutes (new code) Occupational Therapy G0152 Services performed by a qualified occupational therapist in the home health or hospice setting, each 15 minutes (new code description) G0158 Services performed by a qualified occupational therapist assistant in the home health or hospice setting, each 15 minutes (new code description) G0160 Services performed by a qualified occupational therapist, in the home health setting, in the establishment or delivery of a safe and effective occupational therapy maintenance program, each 15 minutes (new code) NHIC, Corp. 75 Sgt. William Terry Drive Hingham, MA 02044 www.medicarenhic.com TMP-EDO-0066 V1.0 Release date: 02/04/2011 The controlled version of this document resides on the NHIC Quality Portal (SharePoint). Any other version or copy, either electronic or paper, is uncontrolled and must be destroyed when it has served its purpose.

NHIC, Corp. MEDICARE ADMINISTRATIVE CONTRACTOR JURISDICTION 14 A/B MAC Speech-Language Pathology G0153 Services performed by a qualified speech-language pathologist in the home health or hospice setting, each 15 minutes (new code description) G0161 Services performed by a qualified speech-language pathologist, in the home health setting, in the establishment or delivery of a safe and effective speech-language pathology maintenance program, each 15 minutes (new code) Skilled Nursing G0154 Direct skilled services of a licensed nurse (LPN or RN) in the home health or hospice setting, each 15 minutes (revised description) Examples include: Wound care Injection Catheterization Ostomy care Scenario: A nurse spends 13 minutes assessing the patient, 12 minutes providing education and 30 minutes catheterizing the patient and performing wound care. The nurse reports her time with G0154. New codes: G0162 Skilled services by a licensed nurse (RN only) for management and evaluation of the plan of care, each 15 minutes (the patient s underlying condition or complication requires an RN to ensure that essential non-skilled care achieves its purpose in the home health or hospice setting) This is not appropriate for the evaluation visit Scenario: The patient does not have skilled nursing needs but has need for a nurse to supervise the nonskilled services because of the multiple chronic problems the patient has. This is reported with G0162. NHIC, Corp. 75 Sgt. William Terry Drive Hingham, MA 02044 www.medicarenhic.com TMP-EDO-0066 V1.0 Release date: 02/04/2011 The controlled version of this document resides on the NHIC Quality Portal (SharePoint). Any other version or copy, either electronic or paper, is uncontrolled and must be destroyed when it has served its purpose.

NHIC, Corp. MEDICARE ADMINISTRATIVE CONTRACTOR JURISDICTION 14 A/B MAC G0163 Skilled services of a licensed nurse (LPN or RN) for the observation and assessment of the patient s condition, each 15 minutes (the change in the patient s condition requires skilled nursing personnel to identify and evaluate the patient s need for possible modification of treatment in the home health or hospice setting) Examples include: Observation of congestive heart failure symptoms Observation of emphysema symptoms Scenario: A patient is referred for nursing services following hospitalization for congestive heart failure. The patient also developed a pressure ulcer during the hospitalization and wound care will be provided as well. On the first visit, the nurse spends 45 minutes assessing the patient and 15 minutes doing wound care. This visit would be reported with G0163. G0164 Skilled services of a licensed nurse (LPN or RN), in the training and/or education of a patient or family member, in the home health or hospice setting, each 15 minutes Examples include: Education about new medications Education about self injecting a medication Training to care for a colostomy Scenario: A nurse spends 10 minutes assessing the patient s physical condition. She then spends 30 minutes teaching the patient and caregiver to draw up insulin in a syringe and do a self injection. This visit would be reported with G0164. NOTE: Only one G-code should be used per visit. CMS recognizes that, in the course of a visit, a nurse or qualified therapist could likely provide more than one of the nursing or therapy services reflected in the new and revised codes above. However, HHAs must not report more than one G-code for the nursing visit regardless of the variety of nursing services provided during the visit. Similarly, the HHA must not report more than one G-code for the therapy visit, regardless of the variety of therapy services provided during the visit. In cases where more than one nursing or therapy service is provided in a visit, the HHA must report the G-code which reflects the primary reason for the visit, which typically would be the service which the clinician spent most of his/her time. NHIC, Corp. 75 Sgt. William Terry Drive Hingham, MA 02044 www.medicarenhic.com TMP-EDO-0066 V1.0 Release date: 02/04/2011 The controlled version of this document resides on the NHIC Quality Portal (SharePoint). Any other version or copy, either electronic or paper, is uncontrolled and must be destroyed when it has served its purpose.

NHIC, Corp. MEDICARE ADMINISTRATIVE CONTRACTOR JURISDICTION 14 A/B MAC Resources: CMS Transmittal 7182: http://www.cms.gov/transmittals/downloads/r824otn.pdf MLN Matters Article MM7182: http://www.cms.gov/mlnmattersarticles/downloads/mm7182.pdf Disclaimer: This job aid was prepared as a service to the public and is not intended to grant rights or impose obligations. This job aid may contain references or links to statutes, regulations, or other policy materials. The information provided is only intended to be a general summary. It is not intended to take the place of either the written law or regulations. We encourage readers to review the specific statutes, regulations and other interpretive materials for a full and accurate statement of their contents. Published April 21, 2011 NHIC, Corp. 75 Sgt. William Terry Drive Hingham, MA 02044 www.medicarenhic.com TMP-EDO-0066 V1.0 Release date: 02/04/2011 The controlled version of this document resides on the NHIC Quality Portal (SharePoint). Any other version or copy, either electronic or paper, is uncontrolled and must be destroyed when it has served its purpose.

Attachment C

Scenario One BKD National Health Care Group Home Health Physician Face-to-Face Encounter Documentation Reference Tool Face-to Home Ordering Face Health Plan of Ordering Physician Activity Physician Encounter Certification Care Community physician refers/orders home health services Scenario Two Inpatient facility physician refers/orders home health services and is willing to accept responsibility for patient after inpatient facility discharge until community physician can assume responsibility Scenario Three Inpatient facility physician refers/orders home health services but is unwilling to accept responsibility for patient after inpatient facility discharge Scenario Four Patient received encounter by physician or nonphysician practitioner who cared for the patient during acute or post-acute inpatient stay but that physician is not accepting resposibility for the patient after inpatient discharge Community physician Inpatient facility physician Inpatient facility physician Community physician Performed by community physician or nonphysician practitioner under community physician supervision Performed by inpatient facility physician or nonphysician practitioner under inpatient facility physician Performed by inpatient facility physician or nonphysician practitioner under inpatient facility physician Performed by physician or nonphysician practitioner during inpatient stay Signed and dated by community physician Signed and dated by inpatient facility physician Signed and dated by inpatient facility physician Physician or nonphysician practitioner who performed encounter communicates findings to community physician who signs and dates certification Signed and dated by community physician Signed and dated by inpatient facility physician Signed and dated by community physician Signed and dated by community physician Revised 12/06/2010 Questions? Contact M. Aaron Little at mlittle@bkd.com.