Medicare's Home Health Certification in a Nutshell
May 11th, 2012
When KLA does consulting with new providers, one of the areas of missed reimbursement we find MOST FREQUENTLY is provider oversight of home health services.
Providers may bill for home health certification and recertification when certain requirements have been met.
Medicare has recently released MLN Matters SE1219 at: http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1219.pdf which itemizing in detail what is expected when a provider certifies a patient for home health.
Of particular interest is the recap on documentation requirements. Specifically:
Face-to-Face Documentation Requirements:
- Documentation must be clearly titled, dated, and signed by the certifying physician, whether as part of the certification form itself, or as an addendum. It must also include the date the face-to-face encounter was performed.
- Documentation includes a brief narrative which describes how the patient’s clinical condition, as seen during that encounter, supports the patient’s homebound status and need for skilled services.
- The face-to-face documentation must be that of the certifying physician, and cannot be altered/changed in any way by the home health agency.
- The face-to-face documentation is part of the certification, and the certification is required at the time the home health agency bills Medicare.
- The face-to-face documentation can include, or exist as, checkboxes so long as it comes from the certifying physician.
- If the physician who cared for the patient in the acute or post-acute facility chooses to use documentation that is compiled from the patient’s medical record (e.g. a discharge summary) to inform the certifying physician of how the clinical findings of the face-to-face encounter support Medicare home health eligibility for that patient, the compiled documentation must be reflective of the clinical findings of that face-to-face encounter as observed by that physician caring for the patient in the acute or post-acute facility, thus serving as that physician’s communication to the certifying physician. Further, if the certifying physician chooses to use the encounter documentation from the informing physician as his or her documentation of the face-to-face encounter, the certifying physician must sign and date the documentation, demonstrating that the certifying physician received that information from the physician who performed the face-to-face encounter, and that the certifying physician is using that discharge summary or documentation as his or her documentation of the face-to-face encounter.One physician signature, from the certifying physician, suffices if the face-to-face encounter documentation is co-located with the physician’s certification of eligibility. Otherwise, if the face-to-face documentation is attached as an addendum to the certification (a separate document), the face-to-face documentation and certification each require a signature from the certifying physician.
- Electronic signatures are acceptable.
The article also details who can perform the face-to-face encounter.
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