Home Health & Hospice Week

Agency can include service length estimate on POC to sign, MAC allows.

The new regulatory requirement for the physician to estimate how much longer the patient will need home health services is still in effect — but a confusing documentation requirement put forth by one MAC is not.

In a June 24 Ask-The-Contractor teleconference, MAC CGS told HHAs that the frequency and duration included on the plan of care doesn’t fulfill the requirement, and that the agency cannot make the

estimate. That still holds true.

But: The MAC indicated the physician would have to write in and sign his or her own statement with the estimate, instead of just signing off on the estimate he or she gave along with the rest of the recertification/ plan of care. That would create a logistical nightmare, industry veterans worried (see Eli’s HCW, Vol. XXIV, No. 25).

Now CGS is backing off of that statement in newly released questions-and-answers from the teleconference. “CMS does not require any specific form or format for the physician recertification estimate,”

CGS says in the Q&As. “Estimates could be included in a verbal order or as a statement on the certification/plan of care. Unless specifically prohibited by [the Centers for Medicare & Medicaid Services],

CGS will allow the provider to include the estimate on the certification for the physician to sign.” 

Watch out: Note the qualification “unless specifically prohibited by CMS,” experts point out. CMS hasn’t yet issued any detailed instructions about this requirement, so the procedure isn’t set in stone.

Now that that concern is dispatched, agencies’ biggest worry about this requirement appears to be full claims denials caused by failure to obtain the physician’s estimate, whether through verbal orders

or a statement on the POC. Be sure to include the information on every recert, or you can kiss your entire episode’s reimbursement goodbye.

Tip: With either verbal orders or the POC, be sure to document that the estimate comes from the physician.

Note: See the new Q&As at www.cgsmedicare.com/hhh/education/faqs/act/act_qa062415.html. For tips on fulfilling the requirement, see Eli’s HCW, Vol. XXIV, No. 25.