A recertification requirement change

Review Choice makes it more important for home care agencies to meet documentation requirements

Are you still obtaining an estimate from the certifying physician about how much longer services will be required still when recertifying a home health patient?

Many home care providers still prioritize the physician’s estimate, even though the Centers for Medicare and Medicaid Services (CMS) has not required it for recertification since the beginning of 2019. Reviewers often make this mistake, too.

“We still see this one frequently,” said J’non Griffin, president and owner of Home Health Solutions. “It’s taking a while for the word to get out.”

In the fluid regulatory environment of home health, keeping abreast of changes and updates poses a significant challenge to home health providers, billers, coders, reviewers and other busy professionals who risk compliance issues when they fail to follow the most recent guidelines and regulations.

“The normal for home health agencies is to be in the process of correcting any mistakes made during the adaptation to the last set of regulations while undertaking the implementation of a complicated new set of regulations – and trying to fit in a few training sessions here or there to learn more about the complex set of regulations coming up next, “ J’non said. “All at the same time.”

The recertification change

It isn’t easy for home care providers to find the latest regulations. In addition to the volume of regulations on the CMS web site, there can be a delay before changes make their way into the Medicare Benefit Policy Manual and Program Integrity Manual.

In the case of the physician’s estimate at recertification, CMS dropped the requirement in its Final Rule for 2019 (83 FR 56406) months ago, and the change took effect on Jan. 1, 2019 -- but it has taken awhile to update the Medicare Benefit Policy Manual and Medicare Program Integrity Manual.

(Here is a link to read more about the Change Request.)

The Code of Federal Regulations (CFR) at 42 CFR 424.22 (b)(2) provides the requirements for recertification of home health patients.

“Note that all other requirements set out in this section of Code remain valid and were not changed when the 2019 Final Rule eliminated the need for the physician’s estimate,” J’non said.

101 documentation tips

More major changes are on the horizon, with a complete overhaul of home health scheduled for 2020 when the new Patient-Driven Groupings Model (PDGM) takes effect.

Medicare's new payment model will launch just six months after Illinois home care agencies kick off the Review Choice demonstration. (CMS announced a June 1 start date for the Review Choice demonstration this week.) Agencies in Florida, Texas, Ohio and North Carolina go next, and are now awaiting announcement by CMS for when the demonstration will begin in their states. These major changes make it more important than ever for agencies to stay abreast of changed or updated documentation requirements, J'non said.

To help agencies shore up their documentation, the Home Health Solutions team has compiled a list of 101 documentation strategies to pass reviewer scrutiny.

Presented in helpful checklist form, “Review Choice 101” identifies common errors and lists documentation strategies for compliance from start of care to recertification, transfer or discharge. It includes face-to-face documentation tips, explains what is needed to establish medical necessity, highlights documentation needed for the new Medication Management Teaching and Assessment (MMTA) clinical grouping under the Patient-Driven Groupings Model (PDGM, covers therapy documentation tips and more. It's designed as a great resource for educating your team one quick session at a time by covering the main point, then reviewing the accompanying checklist of tips and/or common documentation errors.

Available as a digital guide, “Review Choice 101” is on sale for $99 in the Home Health Solutions online store.