In comments submitted to CMS, agencies expressed concern with the proposed electronic clinical template created for doctors to use when documenting face-to-face encounters.
 
The National Association for Home Care & Hospice (NAHC) says its top concern about the voluntary template is the amount of blank space provided — specifically on items used to justify homebound status and the need for skilled care. Blank spaces and prompts within the template are similar to the face-to-face encounter documentation physicians filled out when narratives were required to describe eligibility criteria, NAHC says.
 
NAHC also argues CMS has significantly underestimated how much work it will be for doctors to fill out the template. CMS estimates an electronic template would take a doctor 10 minutes to a complete and a paper version would take 15 minutes. NAHC believes it actually would take twice as long.
 
One commenter from Vermont agreed with that sentiment, saying the template seeks too much information from physicians.
 
The comment period about the template closed Oct. 13.
 
Related link: View NAHC’s comments at http://bit.ly/1MHBdKA. View the template at http://bit.ly/1N5Y3Mp.