Over the past two years, we have seen a dramatic increase in the use of remote care technology in clinical practices of all kinds. With recent reports that the cost of COVID-19 social isolation has reached nearly $7 billion, we may soon see remote care monitoring (RCM) in the home expand exponentially. RCM may soon be considered the “seventh discipline” on many home health plans of care.
Face-to-Face Compliance with Remote Care Monitoring
In home health, we must secure documentation of a face-to-face physician visit with the patient for the same reason we are seeing the patient in the home. The documentation secured for compliance with this rule includes a brief narrative that describes how the patient’s clinical condition, as seen during that encounter, supports the patient’s homebound status and need for skilled services.
How can an organization comply with this requirement when patients are unable to, or refuse to, leave the home due to fear of contracting the virus?
Remote care monitoring is a logical answer to this dilemma.
In fact, CMS directs physicians through documentation, indicating “the face-to-face encounter can be performed via a telehealth service.” For home health organizations struggling to comply with the face-to-face rule, it is in their best interest to make this technology available to all admitted patients who require clinical care and are unable or unwilling to leave their home.
Providers and multiple professional organizations, such as the National Council on Aging, the American Medical Association and the National Association for Home Care and Hospice (NAHC), are attempting to work with Congress to gain support for remote care monitoring reimbursement. Now that the Medicare Payment Advisory Commission (MedPAC) is showing significant interest and getting involved in the conversation, it would appear that we are getting closer to meeting that objective.
Remote Care Monitoring as the “Seventh Discipline”
As we work through the process of using remote care monitoring for ordered virtual visits, we need to understand what is required when surveyors and other auditors review documentation.
We currently have little direction from CMS. However, we have experienced survey and auditor reviews requiring documentation that is strikingly similar to rules now existing for the current six billable disciplines of skilled nursing (SN), physical therapy (PT), occupational therapy (OT), speech therapy (ST), home health aide (HHA) service and medical social work (MSW).
By treating the use of remote care monitoring itself as the “seventh discipline” on the physician’s care plan, we can satisfy the requirements that we see evolving.
Three Tips for a Compliant RCM Plan of Care
- Orders should be very specific in frequency, use and duration. For example, an order may look like this: Remote care monitoring by RN 2 x week x 9 weeks. Remote care monitoring to assess patient’s compliance with current medication regimen, evaluate reported pain level and log being kept by patient for tracking of blood sugars.
- The quality assurance staff within the organization should track RCM visits the same as the frequency and content of other visits.
- Work with your electronic medical record (EMR) vendor to ensure RCM visits are appropriately identified as such. At this point, we cannot bill for RCM visits. If billed, it could be considered fraudulent billing.
RCM is quickly becoming adopted by all healthcare organizations as an alternative treatment of choice in caring for patients in the home. More frequent touch points could significantly change reported outcomes, improving star ratings. Be certain to research the best RCM program for you and your organization.
Axxess Home Health, a cloud-based home health software, includes HIPAA-compliant documentation capabilities on all devices, even without internet access.
