Today, CMS informed the National Association for Home Care & Hospice (NAHC) that it’s reversing its position requiring MA plans to apply Medicare Fee-for-Service face-to-face certification requirements to home health services. Previously, CMS, in its final call letter for 2015 rates for Medicare Advantage (MA) plans, determined that the MA plans would apply the same certification requirements as fee-for-service (FFS) Medicare to plan members who receive home health services. This rule would also require that the plans apply the face-to-face requirement-NAHC had some serious concerns with this directive and spoke to CMS officials about them. NAHC questioned the reasoning behind the requirement, since MA plans have a preauthorization process already in place that would negate the need to follow Medicare FFS certification requirements. In addition, NAHC expressed its interpretation of the regulation to require that the MA plans offer the same scope of benefits to their members as Medicare but need not apply the same certification criteria as Medicare. To see a recent NAHC report article on MA plans, click here.
CMS has shared the following memorandum that it issued to the MA plans on June 11, 2014:
This memorandum is to correct the Final Call Letter of April 7, 2014 regarding Medicare Advantage organization’s (MAO’s) certification of enrollees for home health services. We are clarifying that an MAO’s authorization for home health services may substitute for the Original Medicare face-to-face certification requirement for the authorization of home health care services.
In certain circumstances, MAOs are not required to follow Original Medicare documentation requirements for the provision of Medicare covered services, but may substitute methods they deem appropriate for ensuring that the services provided are medically necessary, so long as they are not more restrictive than the coverage standards that apply in Original Medicare.