A new CMS regulation that will soon take effect requires physicians or qualified non-physician practitioners to certify that a documented face-to-face encounter with a patient occurred when home health services are ordered. The encounter must be certified 90 days before the start of home health care or 30 days afterward, and home health agency staff are prevented from certifying the encounter because of a potential financial conflict of interest.
While the goal — to improve communication between patients and physicians and recommend appropriate patients for home health care — is admirable, experts says the regulation may pose problems for unprepared hospitals. While home care providers are responsible for ensuring that face-to-face encounter certification occurs, hospitals and providers who fail to provide certification could see home care delaying referral acceptance. "If you have the patient waiting for a time to go home, you have the financial burden on the delay of discharge, and you have a patient who is beginning to lose faith that people know what they're talking about," says Jackie Birmingham, RN, MS, vice president of regulatory monitoring for Curaspan Health Group.
Here Ms. Birmingham discusses three things hospitals should do immediately to adjust to the new regulation:
1. Communicate current workflows. If hospital administration fails to communicate with medical staff and case management about the change, Ms. Birmingham says hospitals could experience problems when providers aren't sure who is responsible for the encounter and documentation. "The relationship between a case manager and the physician who's working with the patient on discharge is going to be strengthened," she says. "What needs to happen immediately is that hospital leadership needs to know what staff is doing in their workflow."
She says starting right now, hospital leaders and case management departments should meet and go over the current workflow. "Case management departments should take advantage of this new rule and tell their administrators, 'These are the tasks we're doing now, and this is what we're doing to meet other regulations,'" she says. They can then ask for support from hospital administrators, who can educate providers about their new responsibilities and look into information technology to assist with the additional requirement.
2. Invest in IT to track workflow data. Ms. Birmingham says information technology will be essential to support compliance with the reg on face-to-face encounters. She says if the face-to-face encounters are not performed properly, patients may be sent home without services and then readmitted to the hospital, wasting both time and money for the facility. "You're looking at a potential impact on readmissions, and technology can help eliminate data entry to capture important trending data," she says. "Leadership in a hospital can help mange better financial and clinical outcomes if they have data around their workflow practices." She says IT can also help track changes in delay days, or avoidable hospitalization days for Medicare patients that may jump when home health agencies are waiting for face-to-face encounter certification.
As with any quality improvement effort, hospitals that want to make sure face-to-face encounters are being performed and certified properly and that the new regulation is not adversely affecting hospital readmission rates or delay days. Ms. Birmingham says this means looking closely at reasons for readmission rates or delay days and determining where the problem lies. "Everybody's looking at readmissions, but this involves drilling down on what that means. Are the patients readmitted from home care? Are they readmitted from active care? Was it that the patient couldn't get the face-to-face encounter, so the provider said, 'We'll make the referral later'?"
3. Prepare for problems with patient throughput. Even the best-prepared hospitals may experience some problems with patient throughput as providers adapt to the new regulation, Ms. Birmingham says. "Patient throughput will be impacted, just like it was when Medicare instituted a different rule about patient appeal rights," she says. "Hospitals need to be ready to deal with a lot of red tape. If it's impacting the post-acute world, it will impact hospitals indirectly with length of stay delays." She says the worst thing that could happen is that hospitals who can't provide face-to-face certification may discharge patients without a referral to home health, thereby leaving patients without appropriate care.
She says technology can help ease the burden on providers by cutting time spent on paperwork and easing communication between case managers and physicians. However, as CMS continues to "iron out the kinks" in the new regulation, hospitals should expect some growing pains.
Read more about Curaspan Health Group and its suite of web-based software for patient discharge. Curaspan's software-as-a-service (SaaS) applications enable hospitals and post-acute providers to streamline and coordinate their workflow, communication and care.
While the goal — to improve communication between patients and physicians and recommend appropriate patients for home health care — is admirable, experts says the regulation may pose problems for unprepared hospitals. While home care providers are responsible for ensuring that face-to-face encounter certification occurs, hospitals and providers who fail to provide certification could see home care delaying referral acceptance. "If you have the patient waiting for a time to go home, you have the financial burden on the delay of discharge, and you have a patient who is beginning to lose faith that people know what they're talking about," says Jackie Birmingham, RN, MS, vice president of regulatory monitoring for Curaspan Health Group.
Here Ms. Birmingham discusses three things hospitals should do immediately to adjust to the new regulation:
1. Communicate current workflows. If hospital administration fails to communicate with medical staff and case management about the change, Ms. Birmingham says hospitals could experience problems when providers aren't sure who is responsible for the encounter and documentation. "The relationship between a case manager and the physician who's working with the patient on discharge is going to be strengthened," she says. "What needs to happen immediately is that hospital leadership needs to know what staff is doing in their workflow."
She says starting right now, hospital leaders and case management departments should meet and go over the current workflow. "Case management departments should take advantage of this new rule and tell their administrators, 'These are the tasks we're doing now, and this is what we're doing to meet other regulations,'" she says. They can then ask for support from hospital administrators, who can educate providers about their new responsibilities and look into information technology to assist with the additional requirement.
2. Invest in IT to track workflow data. Ms. Birmingham says information technology will be essential to support compliance with the reg on face-to-face encounters. She says if the face-to-face encounters are not performed properly, patients may be sent home without services and then readmitted to the hospital, wasting both time and money for the facility. "You're looking at a potential impact on readmissions, and technology can help eliminate data entry to capture important trending data," she says. "Leadership in a hospital can help mange better financial and clinical outcomes if they have data around their workflow practices." She says IT can also help track changes in delay days, or avoidable hospitalization days for Medicare patients that may jump when home health agencies are waiting for face-to-face encounter certification.
As with any quality improvement effort, hospitals that want to make sure face-to-face encounters are being performed and certified properly and that the new regulation is not adversely affecting hospital readmission rates or delay days. Ms. Birmingham says this means looking closely at reasons for readmission rates or delay days and determining where the problem lies. "Everybody's looking at readmissions, but this involves drilling down on what that means. Are the patients readmitted from home care? Are they readmitted from active care? Was it that the patient couldn't get the face-to-face encounter, so the provider said, 'We'll make the referral later'?"
3. Prepare for problems with patient throughput. Even the best-prepared hospitals may experience some problems with patient throughput as providers adapt to the new regulation, Ms. Birmingham says. "Patient throughput will be impacted, just like it was when Medicare instituted a different rule about patient appeal rights," she says. "Hospitals need to be ready to deal with a lot of red tape. If it's impacting the post-acute world, it will impact hospitals indirectly with length of stay delays." She says the worst thing that could happen is that hospitals who can't provide face-to-face certification may discharge patients without a referral to home health, thereby leaving patients without appropriate care.
She says technology can help ease the burden on providers by cutting time spent on paperwork and easing communication between case managers and physicians. However, as CMS continues to "iron out the kinks" in the new regulation, hospitals should expect some growing pains.
Read more about Curaspan Health Group and its suite of web-based software for patient discharge. Curaspan's software-as-a-service (SaaS) applications enable hospitals and post-acute providers to streamline and coordinate their workflow, communication and care.