Home Health & Hospice Week

Securing certification prior to billing may not cut it under new guidance.

You’ve got a few more clues to compliance with face-to-face physician encounter rules. The Centers for Medicare & Medicaid Services has issued a revised version of the transmittal updating Medicare Benefit Policy Manual provisions relating to F2F.

Old way: “The certification must be complete prior to when an HHA bills Medicare for reimbursement,” CMS acknowledges in April 22 CR 9119.

New way: That’s still true, but “physicians should complete the certification when the plan of care is established, or as soon as possible thereafter,” CMS insists in the CR. “It is not acceptable for HHAs to wait until the end of a 60-day episode of care to obtain a completed certification/recertification” — which includes the F2F.

“Longstanding policy simply required signed certifications prior to billing,” notes the National Association for Home Care & Hospice. “The policy change adds the requirement that an HHA cannot wait until the end of the episode to try to obtain the signed certification.”

See the 34-page CR at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R208BP.pdf.