Home Health Insight

This information comes from the National Association for Home Care and Hospice:

Effective Jan. 1, 2011, all Medicare home health and hospice certifications and recertifications must be not only signed by the ordering physician, but also must be dated by that physician. During a conference call last week, the Centers for Medicare & Medicaid Services (CMS) advised its contractors of this interpretation of the final rule updating the home health prospective payment system for 2011 that was published in the Nov. 17 Federal Register.

According to CMS, this change will be effective for all claims submitted on or after Jan. 1, 2011. CMS referenced current policy manual citations, new home health regulations, and existing hospice regulations and manual citations as the basis for its authority. However, CMS failed to reference longstanding policy found in the home health plan of care instructions that permits fixing the date of receipt of signed orders in lieu of physicians dating their signatures.

The Medicare General Information, Eligibility and Entitlement Manual (Pub. 100-01), Chapter 4, section 30.1 states: “The attending physician signs and dates the POC/certification prior to the claim being submitted for payment.”

Hospices are referred to policy and regulations for physician dates of their signature in the CMS online manual Medicare General Information, Eligibility and Entitlement Manual (Pub. 100-01), Chapter 4, section 60, which states: “Certification statements must be dated and signed by the physician.” And the regulation in the November 17 Federal Register 42CFR 418.22 (b)(5) effective Jan. 1, 2011 states: “All certifications and re-certifications must be signed and dated by the physician(s).”

On Oct. 20, I posted about how OASIS claims are required for payment. I have received several queries about where the source information can be found. Look below for the answers!

The Federal Register, November 2009 (http://edocket.access.gpo.gov/2009/pdf/E9-26503.pdf) explains: “Rather, we intend that in finalizing this policy, providers will ensure that prior to submitting a final HH PPS episode claim, a provider will have submitted an OASIS, and the HIPPS code on the final HH PPS episode claim will be consistent with the HIPPS on the OASIS validation report. As such, we are implementing the provision to require the submission of OASIS for final claims as a condition of payment, and revising § 484.210″

This pertains to HH PPS claims and Medicare HMOs will most likely have their own requirements.
This information comes from Category 1 Question 1 from CMS(updated 09/09):The comprehensive assessment must include OASIS items for all skilled Medicare, Medicaid, and Medicare or Medicaid managed care patients with the following exceptions: patients under the age of 18, patients receiving maternity services, patients receiving only chore or housekeeping services, and patients receiving only a single visit in a quality episode. The transmission requirement currently applies to Medicare and Medicaid patients receiving skilled care only.

There is so much confusion on this kind of coding. I’ve written about it on my Musings of a Code-a-Holic page.