From: Dailey, Shelly R. <shelly.dailey@anthem.com>
Sent: Friday, February 18, 2022 7:27 AM
To: Brianna Lindell <blindell@mnhomecare.org>
Subject: Re: F2F Clarification for MN Homecare Association

You are correct. This would not be acceptable. It seems very disjointed and confusing. If the physician monitoring care in the community is different than the referring certifying physician they must be identifying and documenting the community physician or allowed practitioner within their medical record. Hope this helps. Shelly

From: Brianna Lindell <blindell@mnhomecare.org>
Sent: Thursday, February 17, 2022 3:57:51 PM
To: Dailey, Shelly R. <shelly.dailey@anthem.com>
Subject: {EXTERNAL} RE: F2F Clarification for MN Homecare Association

This email originated outside the company. Do not click links or attachments unless you recognize the sender.

Hi Shelly,

Thank you for your help on this! As a follow up, can you shed some light on this situation?

Currently, Chapter 7 reads a physician or allowed non-physician practitioner (NPP) other than the certifying provider may sign the POC in absence of the certifying physician/NPP only if this provider has been authorized to care for this patient in the certifying provider’s absence (which isn’t defined).

If a home care agency establishes that the F2F provider that also certified a client to home care services is NOT the provider that signs the POC/485 and as an agency we contacted the clinic and established the F2F/certifying provider was unavailable/absent and the POC signing provider is caring for the patient in his/her absence would this be acceptable practice? I am guessing, if the chart were to be audited, you would look for something in the clinical record stating why the F2F provider and the provider signing the 485 are different?

Thank you!

Brianna Lindell

Regulatory Affairs Manager

Minnesota Home Care Association

1265 Grey Fox Road, Suite 2 | Arden Hills, MN 55112-6929

Direct: 651.240.3380 | Main: 651.635.0607

www.mnhomecare.org | blindell@mnhomecare.org

From: Dailey, Shelly R. <shelly.dailey@anthem.com>
Sent: Monday, January 31, 2022 9:28 AM
To: Brianna Lindell <blindell@mnhomecare.org>
Subject: RE: F2F Clarification for MN Homecare Association

Hello Brianna…. The regulations indicate that if the physician or allowed practitioner completing the face to face encounter and referring the patient for home health is an acute or post-acute care provider referring the patient to home health they may or may not be the certifying physician. For instance, a hospitalist would not be able to monitor home health services and would therefore identify the provider in the community who agrees to monitor home health… On the other hand, if there is a provider (MD, PA, NP for instance) who sees the patient in their office, completes a face to face encounter & refers the patient for home health – they should be the provider monitoring and certifying home health services as there would be no reason why they should be referring the patient to another provider.

The way I understand it, as nothing has changed. The regulations in chapter 7 of the Medicare Benefit Policy Manual have not changed. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c07.pdf

It seems CMS is aware that there is some confusion, and if there are any changes as a result of the inquiry the MACs will work on collaborative education surrounding the topic.

If you have further questions, please don’t hesitate to contact me. Have a great day.

Shelly R. Dailey MSN, BSN, RN, CPHM

Home Health & Hospice

Provider Outreach & Education Consultant

National Government Services

5000 Brittonfield Pkwy

East Syracuse, NY 13057

Phone: (315) 412-3488

Shelly.Dailey@anthem.com | www.NGSMedicare.com | www.NGSConnex.com

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From: Brianna Lindell <blindell@mnhomecare.org>
Sent: Friday, January 28, 2022 1:37 PM
To: Dailey, Shelly R. <shelly.dailey@anthem.com>
Subject: {EXTERNAL} F2F Clarification for MN Homecare Association

This email originated outside the company. Do not click links or attachments unless you recognize the sender.

Hi Shelly,

I am hoping you can help me with something. Last year, CMS came out with the first photo regarding f2f. This lead us to believe it was okay for one community provider to conduct the f2f and another community provider (in a different practice or the same clinic group) be the certifying physician or NPP.

The new text in the final rule seems to contradict this.

Can you provide any insight on what is allowed?