Home Health & Hospice Week

Just because the physician signature rule is an old one doesn't make your claim any less denied in medical review.

The latest Comprehensive Error Rate Testing report found a problem with home health agency claims and physician signatures, reports regional home health intermediary Cahaba GBA. "Specifically,the home health agency bills the final claim prior to the physician signing the [plan of care] or there is no indication of when the physician's signature was obtained," the intermediary says in its March newsletter.

In these cases, reviewers deny the claims altogether.

This is a typical issue for home health agencies,says Chicago-based regulatory consultant Rebecca Friedman Zuber. "It happens to all agencies," Zuber tells Eli.

And agencies might be letting this problem slide a little more these days because intermediaries haven't been doing much medical review of claims, industry experts agree. "Until agencies begin to feel it in the pocketbook, they won't pay attention to these issues," Zuber expects.

Billing an episode without securing the physician's signature on the POC occurs for a number of reasons, notes consultant Judy Adams with Adams Home Care Consulting in Chapel Hill,N.C. The culprit is often a breakdown in the agency's internal processes.

Poor interdepartmental communication can be one reason for mistakes, Adams warns. "The process breaks down because of a lack of communication and coordination between the local office and the billing office or between the clinical staff and the office billing staff."

For example: After a chart review prior to billing, clinical staff send the physician additional clarifying orders for visit frequency or some other identified issue. However, billing staff aren't notified of the late order and bill for the episode anyway,Adams explains.

Sometimes the problem occurs because agencies are having trouble securing the physician's signature altogether, Zuber notes. HHAs must remember "it is the agency's responsibility not to file the claim if the orders aren't signed," she reminds providers.

At stake: It's not just reimbursement that is at issue in these reviews. You could become a target of fraud scrutiny if the problem is a frequent one for you. If medical reviewers "identify a pattern of missing ... signatures it shall be referred to the appropriate PSC/ZPIC for further development," the

Centers for Medicare & Medicaid Services warns in March 16 Transmittal No. 327 (CR 6698).