Home Health & Hospice Week

But watch out for state barriers.

If you’ve erred on the side of caution by not accepting home health orders and certifications from Non-Physician Practitioners, a new Medicare regulation should make taking the plunge easier.

Then: The CARES Act signed into law March 27 broadened home health ordering under Medicare by adding nurse practitioners, clinical nurse specialists, and physician assistants to the list of clinicians who can order home health and certify patients for eligibility. And remarkably, the change is permanent. But the lack of an implementing regulation has been causing many home health agencies to hesitate to implement the change (see Eli’s HCW, Vol. XXIX, No. 15).

Now: In its new COVID-19 Interim Final Rule, the Centers for Medicare & Medicaid Services codifies the change, and makes it retroactive.“These regulations are effective on May 8, and will be retroactively applicable to March 1, 2020,” says the rule published in the May 8 Federal Register.“Enacting these provisions at this time will afford maximum flexibility for providers seeking to order home health care services during the [Public Health Emergency] for the COVID-19 pandemic.”

The rule also confirms that “these regulation changes will become permanent and are not time-limited to the period of the PHE for COVID-19.”

This regulation alleviates concerns about NPPs ordering care and certifying eligibility on the federal level, says National Association for Home Care & Hospice President William Dombi.

This is “a big change for home health,” says Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan.

“A quarter of a million NPs, PAs and clinical nurse specialists are the primary care practitioners for homebound patients,” Dombi says in a release.“We hope this certification capability will find its way to hospice, too.”

However, “there are still some state barriers, primarily in state licensing rules that often require a physician plan of care,” Dombi tells Eli.

Do this: HHAs should check their state regulations to see if such limitations exist, Dombi advises. If so, they should ask the state to change its regs to remove the barriers, he urges.

And this: The Interim Final Rule has a comment period, so you can share your thoughts with CMS until July 7.“We will review and respond to any comments received on this IFC in the CY 2021 HH PPS final rule,” CMS says in the rule.

Plus, watch for more Medicare issuances related to this permanent change.“CMS will be amending additional regulations to reflect these changes ...to include an allowed practitioner’s NPI to be listed on the home health claim,” NAHC points out.

HHH Medicare Administrative Contractor Palmetto GBA already has issued some billing information for the NPPs.For claims with dates of service on or after March 1, NPPs certifying home health patients may bill the usual cert/recert and supervision codes, G0179, G0180, and G0181.

“The descriptors of the three codes will be revised at a later date to include the non-physician practitioner specialties,” Palmetto says in a May 5 post to its website.