Home Health & Hospice Week

Don’t depend on CMS for physician education.

While home health agencies and industry reps press for the Pre-Claim Review program’s total withdrawal, agencies in demo states shouldn’t take chances, experts urge. Follow this advice to make sure you are ready when PCR hits your state:

• Don’t delay. “States slated for Pre-Claim Review need to prepare,” stresses Joy Cameron with the Visiting Nurse Associations of America. “Thus far this is only a pause, not an elimination.”

“We encourage each of our members to get prepared early,” urges Michigan HomeCare and Hospice Association head Barry Cargill in a letter about the delay. The more time you spend preparing, the better your PCR affirmation rates will be.

• Do your homework. HHAs should “review the CMS and MAC websites for information on the demonstration and to work with their MAC for help with submitting requests,” a Centers for Medicare & Medicaid Services spokesperson says.

“The best advice Palmetto GBA can offer the home health agencies is to review and educate using the Medicare Learning Matters SE 1436 article that gives Medicare-enrolled providers an overview of the Medicare home health services benefit, including patient eligibility requirements and certification/recertification requirements,” a Palmetto rep tells Eli. “Providers that properly apply the documentation requirements outlined in this article should understand what is required to submit a Pre-Claim Review request for home health services.”See the article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/se1436.pdf.

• Stay up to date. Both CMS and Palmetto urge agencies to stay tuned for further clarifications and educational offerings that will help them comply with PCR. “We recommend providers routinely visit our website for education materials, job aids, User and Operational Guides, Frequently Asked Questions and take advantage of the various teleconferences, webcasts, webinars and face-to-face education workshops that we will offer over the coming months of implementation,” the Palmetto source offers. “Providers are encouraged to sign up for Palmetto GBA’s listservs in order to stay abreast of all new information, enhancements to processes and upcoming events.”

You can find those resources at www.palmettogba.com/HHH — select Home Health Preclaim Review in the Top Links box.

In its delay notice, CMS promises to offer more education before resuming the PCR implementation schedule. The education will focus on “how to submit pre-claim review requests, documentation requirements, and common reasons for non-affirmation,” the CMS rep says.

• Focus on F2F. Make sure you understand the face-to-face physician encounter requirements, because that will be driving many PCR non-affirmation decisions (see Eli’s HCW, Vol. XXV, No. 11).
• Start educating docs now. HHAs are supposed to be complying with F2F rules all the time, not just because they are slated for PCR review, experts point out. So don’t wait for the demonstration to trigger your F2F improvement efforts.

One of PCR’s biggest difficulties is securing, in a timely manner, adequate documentation from the physician completing the F2F encounter, judges Bobby Lolley with the Home Care Association of Florida. “Physician education … along with changes in [a] provider’s internal process flow need to happen, with or without PCR driving that change,” he urges.

• All HHAs should focus on PCR. It’s not just PCR state agencies that should take notice of the claim review program. “HHAs nationwide should redouble their efforts to ensure that submitted claims are supported by solid documentation and that technical errors are eliminated,” exhorts William Dombi, NAHC’s VP for Law.