Home Health & Hospice Week

Your MAC could request files older than 1 year.

When your HHH Medicare Administrative Contractor asks you for medical records, you can typically count on the fact that the records won't be more than a year old. That time limit however, will be eliminated later this month, and MACs will have more flexibility in requesting older documentation.

Background: Currently, if a MAC requests your records related to claims that are under complex medical review, the MAC can collect documentation "related to the beneficiary's condition before and after a service, but shall not request documentation dating from more than 12 months prior to the date of service unless an exception exists," according to Section 3.2.3.4 of the Medicare Program Integrity Manual.

New way: Now the Centers for Medicare & Medicaid Services has issued Transmittal No. 422, which will go into effect on June 26. The directive will do away with that 12-month lookback period, and does not replace it with a new one. Therefore, the Manual implies that records can be requested indefinitely from the date of service, although it's not clear in the document whether any deadline will be introduced to replace the previous 12-month limit.

The reality is that you most likely retain medical records for much longer than one year anyway, since state statutes of limitation dictate how long you must retain them. In California, for example, home health agencies must keep a patient's records for seven years after discharge, whereas in Illinois the records must be kept for five years beyond the last date of service provided, according to information from the American Health Infor-mation Management Association.

Resources: A link to the transmittal is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/2012-Transmittals-Items/R422PI.html. For a link to AHIMA's record retention summary by state, e-mail editor Rebecca Johnson at rebeccaj@eliresearch.com with "Record Retention" in the subject line.