Home Health & Hospice Week

Regulation:

HHAs Have Unanswered Probe & Educate Questions

Agencies look to hospital P&E program for clues.

Home health agencies now know more about what they’ll be facing under the “Probe & Educate” medical review initiative focused on face-to-face physician encounter compliance, thanks to a Nov. 9 MLN Matters article (see story, p. 314). But the Centers for Medicare & Medicaid Services hasn’t yet addressed some of agencies’ pressing questions.

For example: Many of the F2F Probe & Educate program’s details are similar to the P&E program that CMS ran for hospitals’ 2-midnight rule in 2014 (see Eli’s HCW, Vol. XXIII, No. 20). But in that program, CMS told Medicare Administrative Contractors not to review the 2-midnight rule outside of the P&E program. HHAs would like to see the same instruction applied to F2F.

Also: Under hospitals’ P&E procedure, the number of claims sampled increased significantly after the first few rounds of review. CMS’s MLN Matters article only mentions more reviews of five claims, but agencies wonder if larger claim samples might be in the cards.

Note: More about the P&E initiative is at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Medical-Review/Home_Health_Medical_Review_Update.html.

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