Home Health & Hospice Week

NPs, CNSs, and PAs are officially on the list.

New Medicare regulations regarding who can sign home health certifications and recertifications are on the books — make sure your agency is on top of it.

Reminder: Last year, the CARES Act specified that nurse practitioners, clinical nurse specialists, and physician assistants are “allowed practitioners” for home health certifi­cation purposes, the Centers for Medicare & Medicaid Services recounts in Change Request 12222 released May 11. “This means that in addition to a physician, an ‘allowed practitioner’ may certify, establish and periodically review the plan of care, as well as supervise the provision of items and services for beneficiaries under the Medicare home health benefit,” CMS points out.

But regulatory confusion abounded when last November, CMS updated Chapter 7 of the Medicare Benefit Policy Manual to say that allowed practitioners could sign the plan of care only if they were in the same group practice, the National Association for Home Care & Hospice notes in its member newsletter. NAHC requested a correction.

Now, thanks to a manual update in CR 12218 released May 7, 30.5.3 “Who May Sign the Certification or Recertification” corrects that error, saying in part: “A physician or other allowed non-physician practitioner, other than the certifying physician or certifying allowed practitioner who established the home health plan of care, may sign the plan of care or the recertification statement in the absence of the certifying physician or certifying allowed practitioner. [But] this is only permitted when such physician or allowed non-physician practitioner has been authorized to care for the certifying physician’s or allowed practitioner’s patients in his/her absence,” CMS qualifies.

Don’t overlook: “The HHA is responsible for ensuring that the physician or allowed non-physician practitioner who signs the plan of care and recertification statement was authorized by the physician or allowed practitioner who established the plan of care and completed the certification for his/her patient in his/her absence,” CMS instructs in the update.

Meanwhile, the manual update included in CR 12222 adjusts the language of Chapter 7, Section 30 “Certification and Recertification by Physicians for Home Health Services” to say “physician or allowed practitioner” instead of just physician.

Note: CR 12222 is at www.cms.gov/files/document/r10757gi.pdf and CR 12218 is at www.cms.gov/files/document/r10738bp.pdf.