Beginning January 2015, physicians have been tasked with estimating how much time a patient will remain on service upon recertification. This is not a job for the agency. Only the physician may determine how much longer a patient will require services.
CGS gave a teleconference about this today. My friend from Florida, Sahily sent the handouts and FAQs to me. Click the links and you can have them, too.
Even though the handouts are from CGS, this regulation is drawn from the 2015 final regulations for home health. That means they apply to you regardless of your MAC. If you bill Medicare for home health services, there must be an estimation from the physician of how long a patient will require continuing services on each recertification document.
This is how the final regs for home health effective January 1 of this year read (emboldened text added):
When there is a continuous need for home health care after an initial 60-day episode of care, a physician is also required to recertify the patient’s eligibility for the home health benefit. In accordance with §424.22(b), a recertification is required at least every 60 days, preferably at the time the plan is reviewed, and must be signed and dated by the physician who reviews the plan of care. 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.
It does not state how or where this indication must be included in the certification documents. One suggestion by CGS is to include a line with a blank space for the physician to include a date. They have also indicated that the physician may verbally communicate the information to the agency to be included in an order.
If the latter option is chosen make sure that the physician contact prior to the episode is documented.
Remember, the Nurse’s Signature and Verbal SOC date (if any) on a plan of care is the date that the physician was contacted about the orders that wind up on the 485. Usually, the nurse who performed the recertification notifies the physician and the date of SOC is the same as the date of the recertification. My very strong suggestion is that a separate sentence be included in the summary stating that the MD was contacted and he verbally communicated the date he believes that services will end. That may be overkill but but it isn’t a lot to do to protect your payment.
So that we are all clear:
- The physician must make a determination of how much longer the patient will require home health services.
- This requirement is only on recertification.
- It must be written by the physician or;
- It may be verbally communicated
- Such communication should be clearly documented
This is going to be an easy denial, folks. Like dated signatures, the prior face-to-face grammatical errors, etc., this is considered a statutory denial. It does not matter what kind of care you give and how much the patient benefitted. Your claim can and likely will be denied if this date is not included on recertifications.
Don’t shoot the messenger.