Home Health & Hospice Week

Medicare ups the retention period to 7 years.

The feds may have given you a motivating factor to help physicians maintain and submit documentation for home care patients, but it could increase your medical record workload as well.

Medicare's Conditions of Participation (CoPs) for home health agencies require providers to retain records for five years, notes the National Association for Home Care & Hospice. But a new transmittal from the Centers for Medicare & Medicaid Services ups that retention period to seven years for "written and electronic documents ... relating to written orders and certifications and requests for payments for ... home health services" and other items and services including DME, CMS says in Transmittal No. 431 (CR 7890).

CMS will hold ordering physicians to the same seven-year standard for record retention, it says in the transmittal. And CMS now requires the doc "to provide access to that documentation pursuant to a CMS or Medicare contractor request," the transmittal makes clear.

Consequences: HHAs, physicians, or other providers who fail to retain the documentation or submit it to a contractor upon request may see CMS "revoke the party's Medicare billing privileges," the agency warns. Specifically, "if a provider fails to respond to a letter request for documentation within 30 days of the Medicare contractor's request, the contractor may revoke the provider's Medicare billing privileges and impose a 1-year re-enrollment bar," CMS says in a related MLN Matters article.

Home care providers should consider keeping their records for 10 years, NAHC recommends. That timeframe matches "the requirements in the regulations and the statute of limitation in the Fed-eral False Claims Act," the trade group advises.

The transmittal is online at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R431PI.pdf and MLN Matters article is at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM7890.pdf.