Home Health & Hospice Week

Targeted Probe & Educate:

MAC: Like It Or Not, You're On The Hook For Physicians' Documentation

Tip: Make sure claim is supported before you submit it.

You may not be able to control your referring physicians’ documentation practices, but you do have control over one thing — and it’s important.

Physician face-to-face documentation “is the area of least control for the agency,” acknowledges Joe Osentoski with Quality in Real Time in Troy, Michigan. But home health agencies “can control when they bill.” That means HHAs must “actually look at the face-to-face content and don’t bill the claim until it meets requirements,” he urges.

The same goes for technical denials, although they are usually easier to remedy. “I still have frustration with agencies not removing every technical denial reason prior to billing — plan of care, certification content, signed and dated orders, etc.,” Osentoski tells Eli. “They have nearly full control over these items.”

The theme of the responsibility lying on agencies for documentation is underscored in a recent question-and-answer set from HHH Medicare Administrative Contractor Palmetto GBA.

Question: “We try to get the plan of care back within the first 30 days after doing the evaluation. Sometimes we are unable to even with a physician follow up call. How do you suggest we get it signed?” one agency asked Palmetto in its recently posted Q&A set from its March 4 Medical Review Targeted Probe and Educate (TPE) Teleconference.

Answer: Working with other entities can present challenges, but it is important to have a process in place to get information signed timely according to regulations and to respond to an [Additional Development] request timely,” the MAC responds.

Plus: “Palmetto GBA is working with the physician community to make sure they understand the importance of working with facilities and home health agencies to collaborate information,” the MAC pledges.

Responding by deadline to a MAC’s request is proving difficult because “so many agencies do not have competent billers to identify ADRs and facilitate responses,” Osentoski believes.

HHAs on TPE have seen staggeringly high denial rates. The latest results from MAC CGS revealed a 97 percent denial rate for HHAs and 100 percent denial rate for hospices (see Eli’s HCW, Vol. XXVIII, No. 6). National Government Services hasn’t publicly released TPE results for recent time periods.

Stay tuned: Palmetto GBA is compiling TPE data from the first quarter of 2019, a spokesperson tells Eli. The MAC expects to post the information some time this month.

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