Face-to-Face Template: NAHC Submits Comments

Posted on Sunday, October 18, 2015 10:06 AM

NAHC submitted comments to CMS on the clinical template for the home health face-to-face (F2F) encounter. CMS announced the plan to develop a F2F clinical template in February 2015. It was developed as a tool to assist physicians with medical documentation to support coverage of HHA services. It’s a voluntary template and can be used as a paper or electronic progress note. NAHC expressed concern with the amount of text the proposed F2F template includes, specifically surrounding the justification of skilled services and homebound status. Additionally, NAHC believes there is an error in the Progress Note, regarding the discharging physician as well as conflicting guidance from what other CMS officials have stated regarding co-signatures on the F2F encounter. NAHC believes CMS has underestimated the burden that this proposed F2F template will place on physicians, estimating it will take the physician twice as long to complete the Progress Note than what CMS estimated. Once CMS reviews the comments, the template will go through the Office of Management and Budget approval process so it may take several more months before the template is available. Click here to read more.

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