Home health agencies new compliance and documentation requirements

Medicare announced clarifications to home health payments in MLN Matters®Number: MM9119 (Related Change Request (CR) #: CR 9119 on April 10. The clarifications instruct physicians, non-physician practitioners, and home health companies, including hospices, how to submit claims for home healthcare services provided to Medicare patients for episodes beginning on or after January 1, 2015. The article sets forth major changes to home health documentation requirements and finalizes clarifications and revisions to policies regarding physician certification and recertification of patient eligibility for Medicare home health services in the calendar year 2015 and sets forth a revised timeframe for therapy functional reassessments. Beginning on January 1, 2015; at least every thirty calendar days a qualified therapist (instead of an assistant) must provide the needed therapy service and functionally reassess the patient.

The physician narrative requirement for home health certification has been eliminated but prior to certifying a beneficiary’s eligibility for the home health benefit, the certifying provider must have a face-to-face encounter with the beneficiary. Following are the three changes to the face-to-face encounter requirements:

• CMS is eliminating the narrative requirement. The certifying physician is still required to certify (attest) that a face-to-face patient encounter occurred and document the date of the encounter as part of the certification of eligibility. For medical review purposes, Medicare requires documentation in the certifying physician’s medical records and/or the acute or post-acute care facility’s medical records (if the patient was directly admitted to home health) to be used as the basis for certification of patient eligibility.
• If a HHA claim is denied, the corresponding physician claim for certifying or re-certifying patient eligibility for Medicare-covered home health services is considered non-covered as well because there is no longer a corresponding claim for Medicare-covered home health services.
• CMS is clarifying that a face-to-face encounter is required for certifications, rather than initial episodes; and that a certification (versus a re-certification) is generally considered to be any time a new start of care assessment is completed to initiate care.

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