Home Health & Hospice Week

A number of provisions in the recently enacted health care reform package will affect home healthagencies. Don't assume they won't be a big deal just because they aren't solely reimbursement-focused.

Several new Patient Protection and Affordable Care Act (PPACA) requirements have program integrity (PI) motivations, said Lori Anderson with the Centers for Medicare & Medicaid Services at the National Association for Home Care & Hospice's March on Washington annual meeting.

One PI-driven provision tells CMS to implement a requirement that ordering physicians see patients face to face before certification, Anderson said in the April 12 session.

An amendment to the legislation allows other professionals such as nurse practitioners, physician assistants, and midwives to have the face-to-face encounter with the patients before certification, Anderson said. But the physician still must perform the actual certification, after being informed of the visit results by the affiliated professional.

A physician can also use telehealth for the face-to-face encounter, as long as she complies with all current telehealth rules under Medicare, Anderson added.

Wiggle room: The legislation does leave it up to CMS to propose a timeframe for the face-to-face encounter, Anderson pointed out.

The reform package also requires physicians to be enrolled in the Medicare Provider Enrollment,Chain, and Ownership System (PECOS), Anderson said. Durable medical equipment suppliers have had big problems getting their ordering physicians to enroll in PECOS, since the requirement has no direct reimbursement impact on docs.

Warning: If HHAs can't get ordering docs to enroll, agencies' claims will be rejected. And the deadline for the new requirement is July 2010, Anderson stressed.

Considering that CMS had delayed the DME PECOS requirement until 2011 due to operational difficulties, agencies might expect to see delays on the HHA PECOS front too, industry veterans expect.