OIG Assesses Compliance With Physician Documentation of Home Health Face-to-Face Encounters.

Date posted: May 7, 2014

The Department of Health and Human Services Office of Inspector General (OIG) recently released results of its’ study on physicians’ compliance with the Affordable Care Act requirements for documentation of home health face-to-face encounters.  The OIG found that the documentation for 32 percent of home health claims that required face-to-face encounters did not meet Medicare requirements, resulting in $2 billion in incorrect payments.  Further, physicians were inconsistent in completing the narrative portion of the face-to-face documentation; and CMS had minimal oversight of the face-to-face requirement.

The OIG made the following recommendations to which CMS concurred: (1) require a standardized form to ensure physicians incorporate all requirements for the face-to-face documentation; (2) form a strategy to communicate directly with physicians about the face-to-face requirement; and (3) form additional oversight methods for the face-to-face requirement.


Department of Health and Human Services Office of Inspector General.  “Limited Compliance with Medicare’s Home Health Face-To-Face Documentation Requirements.”  OEI-01-12-00390.  10 Apr. 2014.

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