CMS has updated the Medicare Benefit Policy Manual, Chapter 7, with Change Request (CR) 9119, relating the requirements for physician certification and recertification. This CR also updates the timeframe required for therapy functional assessments. The CR, however, leaves questions for providers regarding CMS’ expectation for implementing some of the new provisions. NAHC is currently seeking answers from CMS.
CMS states it has eliminated the narrative requirement from the face-to-face (F2F) encounter document. However, the certifying physician is still required to certify that a F2F patient encounter occurred. The encounter document should include the date of the encounter, be related to the primary reason the patient requires home health services, and be performed by an allowed provider type.
In the updated manual revision, CMS affirms a new requirement for documentation that was stated in the 2015 HH PPS Final Rule. When a patient is admitted to home health directly after discharge from an acute or post-acute care setting and the physician who cared for the patient in that setting is the certifying physician, but will not be following the patient after discharge, the certifying physician must identify the community physician who will be following the patient. CMS says the certification must be completed prior to when the home health agency bills Medicare. CMS reiterates that is not acceptable for HHAs to wait until the end of a 60-day episode of care to obtain the completed certification/recertification.
Click here to view CR 9119.
Click here for more detailed information regarding CR 9119 from NAHC.