Residents performing Encounters for Face to Face

CMS considers residents to be NPPs (Non-physician Providers)along with PAs and NPs; however, Residents in some CMS Q & As, are denied the ability to perform an encounter unless the physician with oversight attests to their physical presence and consultation with the Resident during the encounter visit. Face To Face rules for Residents it seems should mirror those for the NPs and PAs but there exists a lack of clarity for what a Resident can and cannot do in regards to Face to Faces. What guidelines do your agencies observe when managing Face To Faces when Residents are involved?

Joy L Beaver RN, MSN, MBA COS-C
Corporate Quality Department

Comments

  • Some facilities have specific section where it states: this serves as a F2F .. SN for this and that., Homeboud and so forth., either written by PCP., consult or residents., as you mentioned., with a last paragraph from the Supervising MD that ., patient was examined with his presence., Resident's notes was reviewed and Provider is in agreement., for consultants req Home Health services., we have the PCP write a quick note somewhere in the hospital records that he has reviewed the records and agree with the request for HH service request., AND a clinic visit in 1 week., so far this has been accepted., for the hospitals that don't have that section for the F2F .. it is just a paragraph that states what is req SN or PT .., due to.. and home bound status., so far no rejection yet.
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