Home Health ICD-9/ICD-10 Alert

Question: I am confused about documenting onset and exacerbation dates in the plan of care for our patients' primary diagnoses. Is this required by CMS? If so, why?

Answer: The Centers for Medicare & Medicaid Services (CMS) has no requirement for onset and exacerbation dates on the diagnoses. It has only been a recommendation given by the intermediaries.

Now that CMS has directed that the intermediaries cannot have provider manuals but must refer providers to the Medicare Internet Only Manuals (IOM), there is no guidance for onset and exacerbation dates at all.

When a claim is pulled for medical review, the intermediary will use any information included in the medical record to support payment of the services billed. A denial would not be made solely because a provider failed to include a date of onset or exacerbation.

However, including information regarding new onset and recent exacerbation for diagnoses can help to support medical necessity of services. CMS is expected to issue new instructions on plan of care requirements now that there is no official 485 form and the HIM-11 manual has been replaced by the IOMs.