CMS May Soften Paperwork Requirements For Home Health Care

Doctors may not have to write a narrative summary for patients needing home health care if a proposed rule by the Centers for Medicare and Medicaid Services is finalized.

For Medicare to pay for a home health visit, which includes physical therapy, speech therapy and skilled nursing care, the patient must be seen by a doctor either 90 days prior to the start of the home health care or 30 days after the start of the services. Currently, Medicare also requires that physicians certify that these patients are under their care and that they have trouble leaving home without the help of a walker or special transportation because of an illness or injury. To do so, doctors have to fill out what’s referred to as a face-to-face document, which states when the doctor saw the patient, and includes a narrative summary stating why the patient is homebound.

Home health agencies have pushed back against these requirements, saying Medicare contractors have denied them payments if physicians’ summaries are too short and not descriptive enough. And physicians have little incentive to do it a second time since the patient has already received care, according to home health sources. Hospital physicians may also not have enough of a full picture of the homebound status of a patient to write detailed summaries, and primary care physicians might not be in the know if a patient becomes homebound after a hospitalization.

At Pointe Coupee Homebound Health Services in New Roads, Louisiana, Administrator Jeanine Thibodeaux said that the agency had about $15,000 worth of home health denials because Medicare contractors deemed the narrative summaries not complete.

“We had a client that we provided speech therapy for, and the patient had a follow-up appointment for the face-to-face, but the patient is diabetic, and wasn’t able to make the appointment so was out of the 30-day window.  … So our agency had to absorb the cost,” she said.

Though the removal of the narrative summary is good news for home health agencies, CMS included a short proposal that could prove just as problematic. The agency says that the Medicare contractor could just look at the hospital or primary care physician’s  medical record of the patient to verify the patient is homebound, still putting the responsibility on the physician to document homebound status, according to Mary Carr, associate director for regulatory affairs at the National Association of Home Care and Hospice. Stakeholders can comment on the proposed rule until the end of August, and then CMS must finalize that part of the rule by November. Until then, Carr says, it will be unclear how Medicare contractors will apply the physicians’ records.

“How do we appeal to someone else’s documentation?” Carr asked. She said NAHCH plans on submitting ideas on how to integrate the home health record or care plan to the medical record so that a Medicare contractor would more clearly see that the patient is homebound.

Meanwhile, despite CMS’ proposed change, the NAHCH still plans to pursue a lawsuit it filed June 5 to get relief for past claims denied and claims that may occur between now and when the proposed rule goes into effect in 2015.

“There is currently a huge backlog of denied claims that need to be resolved and some of these are retroactive going back several years. Medicare patients who are so sick that they cannot leave home without assistance are being denied access to home care services, and home care agencies are foregoing reimbursements,” said Val Halamandaris, NAHCH president.

By Lisa Gillespie



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