Home Health & Hospice Week

Keep an eye on this issue, though.>

What looked to be a big regulatory headache for Clinical Nurse Specialists and Nurse Practitioners in home health has gone away.

Then: A Medicare Benefit Policy Manual update the Centers for Medicare & Medicaid Services issued on March 25 addressed CNSs and NPs with regards to certifying and recertifying beneficiaries for eligibility, ordering home health services, and establishing and reviewing the care plan. The update stated that “Clinical nurse specialist means an individual … who is working in collaboration with the physician” and “Nurse practitioner means an individual … who is working in collaboration with the physician.” The update claimed that “Individual states have varying requirements for conditions of practice, which determine whether a practitioner may work independently without a written collaborative agreement or supervision from a physician, or whether general or direct supervision and collaboration is required; however, a CNS and NP must work in collaboration with a physician … even if state laws governing collaboration do not exist.” The change was going to be retroactive to Jan. 1.

Now: A new CR and MLN Matters article released June 6 “removed information on the definition of an allowed practitioner,” CMS notes in the article at www.cms.gov/files/document/mm12615-update-chapter-7-home-health-services-medicare-benefit-policy-manual-pub-100-02.pdf.

Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan, praises CMS for quickly amending the problem.

But the issue may not be over quite yet. “Although CMS’ rescinding Transmittal 11386 pulls back that policy and places a hold on enforcement, CMS is still deliberating their policy position on the requirement for FPA NPPs to document their scope of practice and relationships with physicians,” warns the National Association for Home Care & Hospice in its member newsletter.