Wednesday, November 5, 2014

Final Rules Eliminate Face-To-Face Narrative Beginning January 1, 2015

CMS has finalized it proposal to eliminate the face-to-face encounter narrative as part of the certification of patient eligibility for the Medicare home health benefit, effective for episodes beginning on or after January 1, 2015.  The certifying physician will still be required to certify that a face-to-face patient encounter, which is related to the primary reason the patient requires home health services, occurred no more than 90 days prior to the home health start of care date or within 30 days of the start of the home health care and was performed by a physician or allowed non-physician practitioner. 

 
For instances where the physician is ordering skilled nursing visits for management and evaluation of the patient's care plan, the physician will still be required to include a brief narrative that describes the clinical justification of the need as part of the certification/re-certification of eligibility.

In determining whether the patient is or was eligible to receive services under the Medicare home health benefit at the start of care, CMS will require documentation in the certifying physician's medical records and/or the acute/post-acute facility's medical records (if the patient was directly admitted to home health) to be used as the basis for certification of home health eligibility.  CMS will require the documentation to be provided upon request to the home health agency, review entities, and/or CMS.

Home health agencies should obtain as much documentation from the certifying physician's medical records and/or the acute/post-acute facility's medical records (if the patient was directly admitted to home health) as they deem necessary to assure themselves that the Medicare home health patient eligibility criteria have been met and must be able to provide it to CMS or its review entities upon request.

CMS will remind certifying physicians and acute/post-acute care facilities of their responsibility to provide the medical record documentation that supports the certification of patient eligibility for the Medicare home health benefit.  Certifying physicians who show patterns of non-compliance with this requirement, including those physician whose records are inadequate or incomplete for this purpose, may be subject to increased reviews, such as provider-specific probe reviews.

CMS is also finalizing the proposal that physician claims for certification/recertification of eligibility for home health services (G0180 and G0179) will not be covered If the home health claim itself is non-covered because the certification/recertification of eligibility was not complete or because there was insufficient documentation to support that the patient was eligible for the Medicare home health benefit.

This final rule does not eliminate the physician narrative for episodes beginning before January 1, 2015 and the thousands of home health denials based on the physician narrative.

This will be discussed in our November 20, 2015Webinar titled "Final 2015 Home Health PPS Rules & Rates".  It will also be discussed at our "Exploring Routes & Trends for Success" Comprehensive Home Health Seminar in Las Vegas on January 28-30, 2015 at the Monte Carlo Hotel & Casino.
The final rule will be published in the Federal Register on November 6th.  We will provide a new link at that time.


Registration Form

We are having another seminar at the same time in the meeting room next door for physicians in Las Vegas.  CMS is also working to decrease physician payments, negatively impact their practices, discourage home health and other referrals, and deny their claims.  You may want to encourage your referring physicians to attend our "Exploring Routes & Trends for Success" Comprehensive Physician Practice Seminar.  We believe it would help them better manage their practice and could improve relations with your home health company.  Information regarding the Physician Practice Seminar is listed below.
 
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Dixon Healthcare Solutions, Inc. Next Destination Seminars 

Exploring Trends &
Routes for Success

Four Great Seminars presented by 
Dixon Healthcare Solutions, Inc.


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Brochures

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Location is the Monte Carlo in Fabulous 
Las Vegas, NV
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Registrations Forms
It is important to register early, because the rates go up as the date gets closer and their is limited seating.
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The speakers include:
Richard Dixon,
J-non Griffin
Robert Liles
Richard Martin
Cheri Martin
Robert Floyd
Donna Floyd
Adam Bird (Physician Practice Only)
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Program Outlines

The program is great for each and we hope to see you in Las Vegas at the Monte Carlo

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