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Physicians unlikely to comply, expert predicts.

The latest versions of the face-to-face physician encounter forms are shorter than originally proposed, but will they be any less burdensome?

Home health agencies may have to wait for the full answer to that question, since the Centers for Medicare & Medicaid Services canceled its April 28 Special Open Door Forum on the form. CMS canceled the call right as it was set to begin.

However, CMS did issue the forms, called the “Home Health Electronic Clinical Template” and “Home Health Paper Clinical Template,” prior to the call. The forms are streamlined over the ones originally proposed (see Eli’s HCW, Vol. XXIV, No. 6).

For example: The paper form is down to 1.5 pages from 5.

However, a shorter form doesn’t mean it will work, notes Chicago-based regulatory consultant Rebecca Friedman Zuber. The latest proposed forms “don’t provide the direction for the kind of detail [HHH Medicare Administrative Contractor] Palmetto wants to see,” Zuber maintains. Claims reviewers “want complete sentences, and detailed and nuanced explanations about why the patient’s medical condition makes them homebound and in need of skilled care. Most physicians are just not going to give us this.”

Even if the form is ideal, there’s only so much it can do, Zuber adds. “A form is not going to solve this problem,” she stresses. “Illinois’ denial rate for the last quarter of data Palmetto gave us based on face to face was 72 percent” (see related denial stats, this page).

Long Way To Go Until Finalization

Even though this is the fourth version of the form, including the one first issued in May 2014, it’s not the final one. CMS continues to take comments on the form at HomeHealthTemplate@cms.hhs.gov, the agency notes on its website.

Timeline: When CMS will issue the final version is unclear. “Once a draft of the template is completed, the template will undergo the required Paperwork Reduction Act (PRA) approval process,” CMS explains. “A release date for the template cannot be determined until the PRA process is complete.”

Even when CMS finalizes the form, you still must decide whether to use it. “Once released in its final approved format, the use of this documentation tool will be voluntary,” CMS points out.

CMS has yet to reschedule the final Special Open Door Forum on the form. However, officials hope to announce the new date by next week, a CMS source tells Eli. The rescheduling may be delayed because CMS offices in Baltimore have closed in response to the Freddy Gray riots.

Stay tuned: The agency will post information about the call on its F2F template website, a CMS representative tells Eli.

Note: See more information, as well as the forthcoming call notice, at .