Home Health & Hospice Week

Estimate needn’t be a separate form or order, MAC says.

Home health agencies are taking a big risk if they aren’t following a new regulatory requirement to obtain the physician’s estimated length of time a patient will need home care services.

Then: In the home health prospective payment system final rule published in the Nov. 6, 2014, Federal Register, the Centers for Medicare & Medicaid Services stated that “In recertifying the patient’s eligibility for the home health benefit, the recertification must indicate the continuing need for skilled services and estimate how much longer the skilled services will be required.” Multiple subsequent transmittals from CMS confirmed the new requirement. HHH Medicare Administrative Contractor CGS told agencies in June that the physician had to complete and sign a separate statement with the length estimate, but then pulled back on the instruction (see Eli’s HCW, Vol. XXIV, No. 25 & No. 26).

Now: “CGS has received clarification from [CMS] regarding the way home health providers should document the requirement that the physician must include an estimate of how much longer the skilled services will be required,” the MAC says in its October newsletter for providers. “The physician’s recertification estimate should be included with other required elements of the recertification and not on any separate form or order.”

That may alleviate agencies’ concerns about having docs complete and sign yet another piece of documentation, but it still leaves agencies on the hook if they fail to obtain the physician’s estimate. And CMS staff and MAC guidance make clear that the doc must generate the length estimate, not the home health agency.

Remember: Frequency and duration included on the Plan of Care do not fulfill this requirement, experts stress.

CGS’s guidance may clear up the confusion about a separate form, but a lot of unanswered questions over this requirement remain, Chicago-based regulatory consultant Rebecca Friedman Zuber tells Eli.

And HHAs need answers fast, because denials for this requirement are just about to hit. “My best bet is that the reviews will start just about today for episodes that began in August,” when CMS announced enforcement of this new rule, notes Julianne Haydel with Haydel Consulting Services in Baton Rouge, La.