Home Health & Hospice Week

Use MAC’s vital Pre-Claim Review checklist.

Home health agencies in Florida should be prepared to hit the ground running when Pre-Claim Review takes effect in three short months.

“Move through the outrage stage quickly,” advises Chicago-based regulatory consultant Rebecca Friedman Zuber, who works with the Illinois Homecare & Hospice Council. “It only wastes precious time.”

Benefit from these PCR prep lessons Illinois home health agencies have learned the hard way:

1. Designate your PCR head. “Decide who is responsible for Pre-Claim Review,” counsels attorney Robert Markette Jr. with Hall Render in Indianapolis. That includes who will collect the required information, who will submit it, and who will field denials and resubmissions, he says. Make sure she is accountable.

2. Take a hard look at your internal processes. “Florida HHAs should do a deep internal review of the sufficiency of documentation on their claims,” advises William Dombi with the National Association for Home Care & Hospice. Pinpoint weak areas for improvement.

3. Map out new internal processes as needed. Palmetto GBA reviewers are looking for very specific items, and some of them may surprise you, Friedman-Zuber notes. You may (justifiably) feel that the MAC is overreaching in its review scope. Her advice? “Just give them what they want,” Friedman Zuber counsels. And provide them even though the MAC’s template doesn’t tell you to (see story, p. 2).

Peruse the many documents Palmetto has posted on its PCR website, including the User Guide and Checklists document posted in the “Job Aids” section at www.palmettogba.com/palmetto/providers.nsf/docsCat/Providers~JM Home Health and Hospice~Home Health Pre-Claim Review, to help determine what you need to submit to secure an affirmation. Palmetto’s “Home Health Pre-Claim Review Submittal Request” form, also available via a link of the same name at that address, can further guide your submission needs and related information-gathering, Markette offers.

Then make sure you have the processes in place to capture that information in documentation, Markette recommends.

4. Get your documentation into docs’ records. It has become apparent under PCR review that agencies will need to get their own documentation signed into the physician record to support most home health claims, multiple sources report.

That is the most important prep step agencies can take, Dombi stresses. Agencies must “incorporate their patient records into physician records.” Palmetto’s PCR instruction materials clearly tell agencies to supplement the physician record with their own documentation that the physician signs, Markette explains. Bolstering the physician record with your records is key.

Make sure your newly revamped internal processes describe how you will ensure that takes place.

5. Reach out to docs. Once you have your process down, educate your referring physicians on what you will need from them when. “Brief physicians on the oncoming documentation demands,” Dombi advises.

Tip: Explain to them that CMS is changing the rules under PCR, so you’ll be needing their information sooner, Markette offers.

Be ready to turn away referrals from physicians who don’t meet your paperwork requirements and deadlines, Markette says.

6. Review eligibility basics. PCR reviewers are hitting the homebound and medical necessity basics hard, agencies report. Make sure your own staff are documenting all the required information when and how reviewers expect.

“Evaluate staff competencies on coverage standards,” Dombi counsels. Then train your staff on shortcomings and any new processes.

Pointer: Resign your staff to the fact that they need to spoonfeed the homebound and medical necessity information to reviewers, Markette recommends.

Note: For a free direct link and PDF copy of Palmetto’s PCR User Guide and Checklists and Submittal Request form, email editor Rebecca Johnson at rebeccaj@eliresearch.com with “PCR User Guide” in the subject line.