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Home health agencies scored one major change in the face to face encounter final rule -- but it comes with its own set of downsides.

Then: Back in July, the Centers for Medicare & Medicaid Services proposed that the same physician had to make the FFE, refer the patient to home care, initiate the home care orders, certify the patient for home care, and sign of the plan of care.

Now: In response to agency protests that that continuity wouldn't work for many patients' hospital stays, CMS has changed the requirement, according to the PPS final rule published in the Nov. 17 Federal Register. A hospital physician is now allowed to make the FFE and document it, initiate orders, and certify the patient for home care, CMS explains. Then the patient's physician in the community can sign the POC.

However, "in the patient's hospital discharge plan, we would expect the hospital physician to describe the community physician who would be assuming primary care responsibility for the patient upon discharge," the final rule notes.

And the hospitalist's documentation would still have to be up to snuff. "If the hospital physician certifies the patient's HH eligibility and initiates the orders for services, the hospital physician could document that a face-to-face encounter occurred and how the findings of that encounter, which in this scenario would have occurred during the patient's acute stay, support HH eligibility," CMS says.

"The ability to have the hospitalist be the physician to do the face to face is [a] positive," cheers Judy Adams with Adams Home Care Consulting in Chapel Hill, N.C. "Sometimes it is difficult to get an appointment with the primary care physician in the community in a timely manner." But beware problems in the transition between the hospital and community physician, says consultant Lynda Laff with Laff Associates in Hilton Head, S.C. "The hospitalist may enter the name of the attending physician that previously cared for the patient," Laff says. But that may have changed since the hospitalization. "The agency would then send orders to that physician, only to find out much later that the MD will not sign orders."

And agencies will probably see this problem increase over time. The use of hospitalists is on the rise "because the attendings feel they lose money making hospital visits," Laff believes. "And hospitals feel that patients receive better care from a hospitalist who is generally more current with treatment and disease and spends more time focusing on treating and discharging patients."