In a policy change that is included in a proposed Medicare payment rule for home health agencies for 2015, CMS has decided to drop the narrative requirement for home health claims. The Patient Protection and Affordable Care Act requires that a Medicare beneficiary have a face-to-face encounter with a physician before the physician can certify that the patient is homebound and in need of skilled care. CMS also required that the physician provide a detailed narrative explaining the patient’s circumstances. Because home health providers saw an increase in retroactive denials of claims based on inadequate narratives supporting the services, CMS has noted in a draft rule issued yesterday that it will eliminate it to simplify the face-to-face encounter regulations. However, physicians would still be required to document the encounter to certify a patient’s eligibility.
*Note: In our experience, we have found that there is often not a lot of information to support a patient’s homebound status in the medical record. CMS will still be looking for the certifying doctor’s medical records (office notes or hospital/SNF records) to see if they support the patient’s HB status and R&N of the ordered service or the face-to-face certification could still be found to be inadequate.
Click here to read more