Physicians must date and sign certs, recerts

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).”

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