Home Health & Hospice Week

F2F reform is what’s really needed, expert urges.

After years of punishing claims denials based on a physician requirement to furnish an estimate of service length for a recert, Medicare is poised to pull back the requirement.

“We are proposing … to eliminate the requirement that the certifying physician must estimate how much longer skilled services will be needed as part of the recertification statement,” the Centers for Medicare & Medicaid Services says in the 2019 Home Health Prospective Payment System proposed rule released July 2.

This idea came from last year’s solicitation in the 2018 HH PPS rule for regulatory burden reduction, CMS indicates in the rule scheduled for publication in the July 12 Federal Register.

“We have determined that the estimate of how much longer skilled care will be required at each recertification is not currently used for quality, payment, or program integrity purposes,” CMS says. “The elimination of this recertification requirement would result in a reduction of burden for certifying physicians by reducing the amount of time physicians spend on the recertification process and would result in an overall cost savings of $14.2 million.”

Eliminating “the redundant physician recertification estimate of continued service is very positive,” cheers reimbursement and appeals expert Joe Osentoski with QIRT in Troy, Michigan. “Too many denials are solely on this basis when there is a clear plan of care and duration of service present.”

Plus: “There have been issues with those home health patients with ongoing needs and no real actual predicted end of home health (such as urinary catheter changes and management), where the Medicare Administrative Contractor has denied the claim due to no date associated with this estimate,” Osentoski tells Eli.

While this change is positive, consultant Pam Warmack with Clinic Connections in Ruston, Louisiana, dismisses it as “straining at a gnat.” Many providers did receive denials initially for the missing estimation statement, but most have since figured out the pretty straightforward requirement. “A great deal of those denials were because the MACs didn’t like where the statement was located. Once we figured out what they wanted and where, the denials began to decline,” Warmack observes.

Instead, HHAs need real change, Warmack urges. “If you want to reduce the burden of useless regulation, eliminate the horrific face-to-face requirement,” she stresses. “I realize the F2F was part of legislation and might require more than CMS can do in this rule, but that is what is truly needed.”