Home Health Articles and Information


Jun 14, 2021 9:38:55 AM / by Kristi Bajer, BSN, RN, COS-C

Face to face is still a problem

Last week Palmetto GBA published the top 5 reasons for non-affirmation and claim denial for their Review Choice Demonstration. The most troubling thing I noticed is the top 3 are all about the same document, the face-to-face.

Here are Palmetto GBA’s face-to-face denial reasons:

  1. The physician certification was invalid since the required face-to-face encounter was not related to the primary reason for home health
  2. The physician certification was invalid since the required face-to-face encounter document (actual clinical note for the face-to-face encounter visit for admissions on / or after 1/1/12...)was missing
  3. The physician certification was invalid since the required face-to-face encounter was untimely and/or the certifying physician did not document the date of the encounter.

The face-to-face process is the first place I look for a point of failure when consulting with a new agency. It is still surprising to find an agency who routinely admits patients without a valid face-to-face. (Yes, I know we are allowed to document a face-to-face completed up to 30 days after the admission) But this practice done routinely, rather than in emergencies, leads to non-billable periods and failed audits.

3 most common problems when admitting without face-to-face:

  1. The patient does not keep appointment in the 30-day window - resulting in no claim
  1. The visit is done but the primary reason for home health has resolved --H&P does not show medical necessity and/or is not related to the primary reason for home health
  1. The referral cost increases exponentially as your staff are paid to call, fax, or otherwise following up-chasing documentation for weeks

Agencies who admit without the face-to-face usually tell me they have to do it for one of two reasons:

  1. Because other agencies do it (so they will lose referrals)
  2. Because the doctors/ hospitals in their area are more difficult than the doctors/hospitals everywhere else

When the face to face  requirement was brand new in 2011, my marketing staff were told over and over by referral sources that we were the only agency requiring this new document. It really worried them and they repeatedly questioned the requirement. Of course it was not true, everyone who was billing Medicare had the same requirement. I am not sure about the psychology here, but it is a recurring theme. Rest assured the referral source tells every agency the same “you’re the only one” story…

Referral sources are difficult everywhere…most aren’t trying to be. They are just extremely busy and have a million compliance requirements of their own.

Here are my best tips for training your referral sources to provide good and timely face-to-face documentation:

    1. Educate your referral sources. A LOT. About everything. They need to think of you as a source of compliant information. Someone who has their back.
    2. Provide cheat sheets and other helpful tools for the referral sources to use for compliance.
    3. Make sure your liaison/marketer/intake person knows exactly what documentation is needed both on the face to face and H&P and have them review it in person or on the phone immediately. Don’t come back and asked for more documentation later…
    4. Finally- and this is the hard one. There must be accountability.
      • Liaisons/ marketers need to be held responsible for the documentation from their assigned referral sources 
      • Referral sources need to understand your agency  will only accept referrals without the correct face to face documentation in rare, special circumstances.
In truth, referral sources who do not provide your agency with documentation for billable referrals, after education and support from your agency, are not good referral sources. Physicians or non-physician practitioners who do not keep proper documentation put themselves and your agency at risk during an audit. 

Tags: PDGM, Value-based care, Compliance, Home Health, Quality assurance, Home Health Care

Kristi Bajer, BSN, RN, COS-C

Written by Kristi Bajer, BSN, RN, COS-C

Kristi Bajer BSN, RN, COS-C, brings over 10 years of real world experience as a clinician, director, and administrator in home health. She is a firm believer in diagnosis driven evidence-based care in home health. Currently, she assists agencies with external chart audits and Medicare appeals, as well as providing training and coaching on OperaCare implementation and building QAPI programs using data to drive success and protect agencies from government audits.