Three years after introducing the Patient-Driven Groupings Model (PDGM), is your agency applying best practices and the right strategies for accurate and compliant coding?
Coding has become more critical and complex with the implementation of PDGM and recent developments of guidelines regarding the relevance of the Face-to-Face Encounter with primary diagnosis coding. On top of that, home health agencies have been inclined to improve their coding practices in response to increased scrutiny from Medical Review and the Review Choice Demonstration (RCD).
Answering the Biggest Questions About F2F Encounter Documentation
As a general rule, the primary diagnosis must receive active treatment during the face-to-face encounter, and this treatment must be clearly documented in the encounter note and reflected in the Plan of Care. Besides knowing the right time to initiate coding, a common confusion for home health providers is determining the situations that require a new Face-to-Face encounter note.
- Since the encounter can be completed within thirty days of the start of care date, can agencies go ahead and code the chart now and get a valid face-to-face encounter later?
No. Though the F2F encounter can occur within 90 days before or 30 days after the SOC, it is highly recommended that coding should be done with an existing F2F encounter note in place. This will avoid auditing issues and extra administrative work to recode the chart. Some agencies finalize the Plan of Care and send it to the certifying practitioner for signature before completing the Face-to-Face encounter visit, which is unacceptable because the certification must include the date of the encounter, which cannot happen until it takes place.
To avoid these issues, it is highly recommended that agencies never code a new Start of Care without an adequate Face-to-Face encounter note.
- Do we HAVE TO get a new Face-to-Face encounter when the clinician finds a wound that isn’t mentioned in the encounter that we have?
Yes. If the clinician discovers a wound that is not documented in the existing encounter note, and if that wound is identified to be the primary reason for home health services (and should be the primary diagnosis on the plan of care), then a new Face-to-face encounter note must be acquired from the physician addressing the wound.
Note: the Face-to-face encounter should always address the reason for home health services.
- Won’t an addendum or diagnosis query and confirmation work?
No. If a wound is the primary reason for home health services and will be coded as the principal/primary diagnosis, it must be addressed and treated during the Face-to-Face encounter. A physician cannot write an addendum for a wound that was not actively treated during the encounter, and a diagnosis query and confirmation will not meet the Face-to-Face requirements.
Auditors look for a diagnosis that is actively treated during the Face-to-Face encounter, and home health principal diagnoses listed without active treatment can cause auditing issues. If the patient had active treatment during the encounter but the physician failed to clearly document the active treatment, then a physician addendum to the Face-to-Face encounter note can be used. However, an addendum written by the home health agency is not allowable.
If there was no active treatment during the encounter, the agency would need a new Face-to-Face encounter.
- In what other instances might a new Face-to-Face encounter be needed?
- When the allowed practitioner documents that the actively treated condition has been resolved
- When the actively treated condition is a diagnosis that is not a PDGM-acceptable primary diagnosis
- When the Face-to-Face encounter is solely a pre-op note and home health will focus on skilled post-op care
- When the Face-to-Face encounter is a note from an in-patient stay and the patient was not directly admitted to home health services following that stay
- When the Face-to-Face encounter is a note from a community physician (urgent care, specialist) that will not be the certifying physician or a non-physician practitioner working under the certifying physician. Also note: when the certifying allowed practitioner is a non-physician practitioner, the community Face-to-Face encounter is required to be done by the same non-physician practitioner.
With these criteria in mind, it appears that many of the Face-to-Face encounters received by agencies may not meet the required standards.
Optimizing Your Reimbursements
Coding is a vital function in home health as it directly impacts both aspects of patient care and the business. While there are strict standards in coding, home health businesses can actually do more to optimize their reimbursements through sufficient documentation, effective care coordination, and the use of best practices.
Proper knowledge and the right strategy are crucial amidst the ever-evolving coding guidelines and payment systems. Many agencies now outsource coding to save time and resources, and quickly adapt to new changes. A specialized provider who can offer scalable support tailored to the agency’s unique coding approach can greatly help home health businesses realize process efficiency and growth.
Read our more comprehensive guide to a compliant F2F documentation here>