Home Health & Hospice Week

Critical: Get docs to incorporate your records — with proof.

A silver lining to the Home Health Pre-Claim Demonstration being up and running in one state is that home health agencies can finally get some practical pointers on how to comply with PCR requirements.

Experts predict that PCR will come to every agency’s doorstep sooner rather than later. By the time the demonstration period launches in five states in January, nearly half of the nation’s HHAs will be under the program, according to data from data.medicare.gov (see Eli’s HCW, Vol. XXV, No. 27). And don’t be surprised to see the feds expand it even further very quickly.

Whether you need to be ready today, next month, or next year, smart agencies will take these steps as soon as possible to mitigate PCR’s potential reimbursement-draining damage:

Pointer #1: “The best advice for HHAs is that they should take steps to incorporate their patient records into the physician record,” advises William Dombi, vice president for law with the National Association for Home Care & Hospice.

That’s because the HHH Medicare Administrative Contractors “appear to be limiting their reviews to the physician record,” Dombi tells Eli.

“That incorporation should take place before the physician signs the certification,” Dombi instructs. “It should also be evidenced by a statement signed by the physician that indicates that the physician considered the record prior to certification.” At least the HHA can develop that statement of incorporation for the physician, he adds.

Pointer #2: PCR denials show that documentation is the key, emphasizes attorney Bob Morgan with Much Shelist in Chicago. “Be proactive in reviewing face-to-face documentation and homebound justification records, developing interdisciplinary documentation trainings, and learning from what has passed muster with MACs,” Morgan urges.

Pointer #3: Lighten your load where you can. Claims exempt from the PCR process are those for Medicare Advantage patients, resumptions of care, and claims under Zone Program Integrity Contractor review, HHH Palmetto GBA says in a PCR Frequently Asked Question set posted Aug. 30.

Palmetto also clarified in a July special Open Door Forum on the demo that agencies don’t have to undergo a new request when services are added to the claim under supplemental orders (see Eli’s HCW, Vol. XXV, No. 28). The MAC reiterates the clarification in the new FAQs, but reminds agencies that “the provider would reflect the HCPCS for those added services on their final claim and assure that the documentation, including the order for those services are maintained in the medical record.”

Pointer #4: Speed up your PCR decision turnaround time by knowing the submission ropes. To receive an electronically delivered “greenmail” decision from Palmetto, you must submit requests via eServices. For CGS, you must submit requests via the myCGS portal and include your fax information to receive a fax.

Reminder: To start receiving decisions via greenmail, “you must be signed up for our eServices online provider portal,” Palmetto explains on its website. “Once you have signed into eServices, select the Admin tab and navigate to the eDelivery Preferences sub-tab. You can then update your eDelivery preferences by simply clicking the drop down box to choose eDelivery, instead of US Mail, for the letters you would like to receive via greenmail. You can also select the User Pref Email Notification checkbox to start receiving emails when your letters are available in eServices for you.”

Pointer #5: Don’t waste time trying to upload attachments with the same name. For the system to accept an attachment, “assure the attachment is named something different than the other attachments previously added,” Palmetto instructs in the FAQs.

Pointer #6: The PCR process is angering physicians and most likely drying up referral streams in the process, agencies fear. Do what you can to minimize the damage by preparing your physicians for the demo’s demands well ahead of time, Morgan recommends. And don’t forget to prepare your own staff, too.

Note: See Palmetto’s PCR site online at www.palmettogba.com (click on “Jurisdiction M Home Health and Hospice,” then click on “Home Health Pre-Claim Review” in the “Top Links” box) and CGS’s PCR site at www.cgsmedicare.com/hhh/medreview/pre_claim_review_demo.html.