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The issue of the home health face-to-face requirement has received a lot of attention recently. When the 2015 Home health Prospective Payment Rule was published, The Centers for Medicare and Medicaid Services (CMS) held an Open Door Forum with subject matter experts and described how this new rule would ease the burden on physicians and ensure that beneficiaries who needed home care received it and that fraudsters would have a more difficult time defrauding Medicare.  A December article on RACmonitor.com written by Ronald Hirsch, MD, with Accretive Physician Advisory Services, reviewed the rule and the Open Door Forum and proposed a simple solution.

But as you heard on the Monday, March 16th Monitor Monday broadcast and read about in a recent RACmonitor.com article by Andrew Wachler and Jessica Forster, CMS appeared to have done a complete 180 degree change on their initial statements. In the latest Open Door Forum, CMS stated that they expected the physician to document the homebound status and need for skilled services in their progress note or discharge summary and it would not be acceptable for the home care agency to document these elements and have the physician review and sign that documentation and incorporate it into the patient’s chart. The listeners to that call repeatedly questioned the presenters about this reversal in policy but the CMS representatives were unwavering in their interpretation.

Fortunately it appears that the power of the press and the industry to effect change worked because on March 23, CMS updated the Home Health Medical Review webpage, stating, “In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services.  Per 42CFR 424.22 (a) and (c), the patient’s medical record must support the certification of eligibility and documentation in the patient’s medical record shall be used as a basis for certification of home health eligibility.  Therefore, reviewers will consider HHA documentation if it is incorporated into the patient’s medical record and signed off by the certifying physician.   More guidance will follow regarding the review of home health claims shortly.  CMS apologizes for the confusion.”

This appears to be a wholesale retraction of all the guidance provided on the last Open Door Forum call, and a reversal back to their original position of allowing the home care agency to document the qualifications and the physician to simply review and sign the document. But until they hear it from the CMS representatives on the next Open Door Forum call, hospital representatives and home care agencies are unlikely to believe it.




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