Confusion Clouds New Documentation Rule


A newly implemented rule (PDF) requiring hospitalists and others who order home health services for Medicare patients to document face-to-face encounters has left SHM and other physician groups searching for clarity.

Under a Centers for Medicare & Medicaid Services (CMS) guideline that took effect April 1, physicians need to show proof of documentation before a patient can receive home care services. The documentation is known as a "certification form," and, either on the form or as an addendum to it, physicians must show that they either they saw the patient or allowed a nonphysician provider to do so. CMS is allowing such documentation (PDF) to be generated from an electronic health record.

Some industry watchers say that despite the deadline, many hospitalists are unaware of the rule. And many of those who are aware are confused as to whether any additional paperwork is required of them, creating the potential for an overwhelming paperwork burden being placed on hospitalists.

SHM and other professional societies, including the American Medical Association (AMA) and the American Hospital Association (AHA), asked CMS to delay the implementation until July 1, in the hopes that more time would help clear up any confusion. CMS declined.

In a letter to CMS Administrator Donald Berwick, MD, last month the AMA wrote, "it is our hope that CMS will reconsider its decision not to further delay the home health requirement and that in the future, imposition of policies … would be discussed with the medical profession BEFORE they turn up in a proposed rule." In addition, CMS needs to significantly improve its education efforts for physicians."

Ryan Genzink, PA-C, of IPC/Hospitalists of West Michigan in Grand Rapids says his hospital began using a new form just to document face-to-face encounters, until he learned from SHM that adding the information to existing documentation could satisfy the new rule. Genzink fears hospitalists around the country are operating under a patchwork of forms and guidelines, which can be a waste of time and money.

"The primary barrier to compliance is the paperwork burden on physicians," SHM and other trade groups wrote to CMS in March. "...The solution to the documentation concerns lies within CMS authority."

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