Home Health & Hospice Week

Are you having a tough time securing required certification documentation from referring physicians? Referring docs to a new CMS compliance tool might help.

The Centers for Medicare & Medicaid Services has issued a new compliance education document, "Provider Compliance Tips for Home Health Services," which actually seems aimed largely at physicians. The MLN fact sheet is intended for "Physicians who refer beneficiaries to home health, order home health services, and/or certify beneficiaries' eligibility for the Medicare home health benefit," as well as home health agencies and non-physician practitioners, it says.

The problem: "The Medicare Fee-For-Service (FFS) improper payment rate for home health claims for the 2017 reporting period was 32.3 percent, accounting for 16.6 percent of the overall Medicare FFS improper payment rate in 2017," the fact sheet notes. "The projected improper payment amount for home health claims during the 2017 report period was $6.1 billion."

The tip sheet continues, "Insufficient documentation accounted for a large proportion of improper payments for home health services. The primary reason for these errors was that the documentation to support the certification of home health eligibility requirements was missing or insufficient documentation to support the certification of home health eligibility requirements. Medicare coverage of home health services requires physician certification of the beneficiary's eligibility for the home health benefit."

The solution: The sheet emphasizes that "physicians or Medicare allowed NPPs must certify" certain elements, and highlights that "the certifying physician's medical record ... for the beneficiary must contain information that justifies the referral for Medicare home health services. This includes documentation that substantiates the beneficiary's need for the skilled services and homebound status." CMS goes on to list the elements that should be documented.

Plus: "The certifying physician medical record for the beneficiary must contain the actual clinical note for the face-to-face encounter visit that demonstrates that the encounter: occurred within the required timeframe; was related to the primary reason the beneficiary requires home health services; and was performed by an allowed provider type," the tip sheet adds.

Links to the sheet are at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/MLN-Publications-Items/ICN909413.html.