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Use these 9 tips to get ready for the new requirement by Jan. 1.

The earlier you get started training docs on the new face to face encounter requirement, the less trouble you’re likely to have with denied payments when the rule takes effect in the new year.

Starting Jan. 1, Medicare will require physicians to perform a FFE either 90 days before or 30 days after the start of care (see related story, p. 322). The legislatively mandated rule aims to increase physician accountability in home care utilization, the Centers for Medicare & Medicaid Services says in the prospective payment system final rule published in the Nov. 17 Federal Register.

Despite numerous suggestions from the industry to scrap the FFE rule altogether, CMS can’t do so because it’s required by law, the agency repeatedly points out in the regulation. That means

HHAs have to come to terms with the requirement right now, or face possible payment denials. Consider this expert advice when getting into compliance with the FFE rule:

1. Start physician education yesterday. The complex FFE regulation takes effect in just more than a month, which doesn’t give agencies very much time to get referring physicians ready for the big changes. Agencies should educate their referring physicians between now and the beginning of the year, recommends Chicago-based regulatory consultant Rebecca Friedman Zuber.

Clients of consultant Pam Warmack have already started their physician education efforts, Warmack reports.

2. Include non-physicians in your educational efforts. Address FFE education to hospital discharge planners and hospital social workers in addition to referring physicians and their staff,  suggests Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C.

3. Use multiple education modes. Conduct education both face to face and in writing to achieve maximum effect, advises consultant Lynda Laff with Laff Associates in Hilton Head, S.C.

4. Keep it short. No one wants their time wasted. Keep your education effort clear and concise, Laff urges -- “the more concise the better.”

Warmack’s clients are giving physicians “cheat sheets” that outline the new rule and provide bullet points of exactly what the required documentation must contain, she says.

Laff suggests developing a “short one-page informative letter” that agencies send to the physician offices -- “both to the MD but also to the lead office administrator/nurse/technician to clearly explain the new regulation.”

5. Don’t expect smooth sailing. “Of course there will be push back by some physicians,” Laff predicts. “It seems like different regions have more problems than others -- usually you see it with older physicians who do not respond well to change.” Explain to referral sources that if they don’t comply with the new requirements, their patients won’t be able to access home care services.

You should explain the access ramifications up front in your informational letter, Laff counsels.

6. Work with docs on scheduling. Don’t wait until the last minute to secure your patients’ visits with their physicians. Before the rule even takes effect, “try to set up arrangements with office staff … to meet to develop a plan for scheduling office visits for home care patients,” Laff recommends. Once a visit scheduling plan is in place, using it to make new appointments should keep FFE-related errors to a minimum.

7. Develop your FFE-related policies, procedures, and processes. Before you’re thrown in the thick of it, “develop the agency’s processes for obtaining the [FFE] information -- who will be responsible, what to do if the physician does not fulfill the requirements, etc.,” Adams advises. Be sure to carefully think through the actions you’ll take if a physician doesn’t comply with the FFE requirements, Zuber urges. In the final rule, CMS says agencies may not bill patients because they or their physicians fail to fulfill FFE rules.

8. Follow through on your P&P. You’ll have to make sure your claims comply with the FFE rule or risk non-payment. That means letting “noncompliant physicians know that [your agency] cannot take their patients unless they are willing to do what is required,” Zuber suggests.

Tip: Home health agencies should work through their medical directors (if they have one) or with the hospital medical staff where the physician practices to influence a non-compliant physician’s behavior, Zuber says.

End result: It might feel hard to take a tough stance with referral sources, Zuber acknowledges. But “if agencies begin telling prospective patients that they cannot admit them because their physician will not complete the required paperwork, either the physicians will begin to comply or the patients may change doctors when and where they can,” she suspects.