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Phase 2 of Face-to-Face (F2F) Probe and Educate

The Centers for Medicare & Medicaid Services (CMS) announced on Dec. 22nd Phase 2 of the home health Face-to-Face (F2F) encounter Probe and Educate. Contractors may begin requesting medical records after Dec. 15, 2016. To review the announcement, please read MLN Matters article SE 1635, which is a revision of MLN Matters article SE 1524 that announced Phase 1 of the same probe.

CMS is continuing the process that was established in Phase 1. It is directing Home Health MACs to select a sample of five claims for pre-payment review from each Home Health Agency (HHA) within their jurisdiction, excluding those providers who had five claims reviewed in Round 1, with zero or one claim in error. As they are completing the second round of Probe and Educate reviews, MACs will continue to focus on the HHA's compliance with the policy outlined in CMS-1611-F and make sure all other coverage and payment requirements are met. Once the review is complete, a letter will be sent to the provider with an explanation of the review results. Providers will have an opportunity for one-on-one education sessions with the medical review contractor. Please note the action CMS has directed the MACs to take based upon their finding.

Source: MLN Matters article SE 1635

Source: MLN Matters article SE 1635.

Contractors plan to begin Phase 2 in mid–late January 2017. The effected dates will be for episodes that start on or after Oct. 1, 2016.

Only agencies that have requested and received education from the medical review contractor on the Phase 1 review results should be subject to Phase 2. Any agency still waiting for a requested education session should contact their medical review contractor to ensure an education session is scheduled prior to any claim reviews for Phase 2.

Phase 1 resulted in a high rate of claims denials for agencies related to the F2F encounter and the physician certification for Medicare eligibility. LeadingAge NY will keep members posted on the finding from the Phase 2 results.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871