Home Health & Hospice Week

Remain vigilant about this CoP requirement.

Just because you haven’t seen denials for patients’ plans of care lacking advanced directive information doesn’t mean they aren’t coming.

Reminder: The Home Health Conditions of Participation that took effect in January 2018 require agencies to have information related to a patient’s advanced directives in the Plan of Care. Earlier this year, the National Association for Home Care & Hospice discovered that CERT audits “uncovered significant noncompliance with this new requirement” and raised fears about mass retroactive denials. Subsequently, all three HH Medicare Administrative Contractors issued statements on the topic that ranged from indicating retroactive claims adjustments weren’t necessary to urging appeals of Comprehensive Error Rate Testing denials on the topic (see Eli’s HCW, Vol. XXVIII, No. 3).

While drastic retroactive denials may have been averted, HHAs were put on notice to include the advance directive information in the POC. And a provider asked a related question in MAC Palmetto GBA’s May 2 Ask the Contractor Teleconference that emphasizes the importance of compliance.

Question: “If we have advanced directives on our initial plan of care (POC), but it got dropped off on the recertification, is that a reason for denial for payment?” the agency asked Palmetto.

Answer: “Palmetto GBA is not currently denying for this,” the MAC responds in its recently released Q&A set. “However, other review contractors may. It is important to ensure advanced directive information is in the POC.”