Agencies continue to struggle with the requirements for the face-to-face encounter documentation, according to Medicare administrative contractor (MAC) Palmetto GBA.
 
The MAC recently published the top denial reasons under medical review for July-September 2022.
 
Nearly two out of every five claims denied was due to the face-to-face encounter requirements not being met.
 
Palmetto’s guidance on the F2F notes specific documentation related to face-to-face encounter requirements must be submitted for review. This includes, but is not limited to, the following:
  • The certifying physician must document that he/she or an allowed nonphysician practitioner (NPP) had a face-to-face encounter with the patient, including the date of the encounter
  • The documentation of the encounter must include a brief narrative, composed by the certifying physician, describing how the patient’s clinical condition as observed during that encounter supports the patient’s homebound status and need for skilled services
  • The certifying physician must document the encounter either on the certification, which the physician signs and dates, or on a signed addendum to the certification
  • The certifying physician may dictate the face-to-face encounter documentation content to one of the physician’s support personnel to type. The documentation may also be generated from a physician’s electronic health record.
In a close second in terms of claims denied, accounting for more than a third of all claims, was an automatic denial due to the requested records not being submitted.