Is Your Recertification Process Compliant?

Home Health Agencies Should Review Immediately.

On Friday, July 10, 2015, CMS issued “Change Request (CR) 9189: Medical Review of Home Health Services” with an implementation date of August 11, 2015. The change request was published in response to clarification and guidance requests regarding several items including the requirement that home health agencies have physicians include an estimate of how much longer skilled services are required on recertifications. This requirement was included in “Change Request (CR) 9119: Manual Updates to Clarify Requirements for Physician Certification and Recertification of Patient Eligibility for Home Health Services” issued on April 22, 2015 with an implementation date of May 11, 2015.

HEALTHCAREfirst reached out to CMS to ask them to clarify the differences in implementation dates between the two CR’s based on concerns from providers who were worried their recertifications between May 11th and July 10th would be out of compliance and based on industry confusion that the existing frequency and duration included in a recertification document met the requirement. While CMS did not specifically state whether or not episodes in that timeframe would be at risk upon implementation of the new interpretive guidance on 8/11/2015, they did say CR 9189 built upon the requirement first introduced in CR 9119.

To ensure compliance with both change requests, HEALTHCAREfirst recommends agencies immediately review their recertification processes and all episodes beginning on or after May 11, 2015. Medicare Administrative Contractor CGS posted a Q&A late Friday with additional instructions for episodes beginning May 11. It includes the following:

  • Q: With implementation of May 11, 2015 for the physician estimate of length of service, if we have not billed yet, is it permissible to go back and request that from the physician even thought it would have a current date for that episode? A: The physician could attest what he would have estimated the amount of time for services back at the time of the physician recertification.
  • Q: Change Request (CR) 9119 is effective May 11, 2015. Would it be reasonable that Medicare would not deny claims because of the late rollout? Is there a way Medicare could potentially document a later effective date for requiring that documentation? A: CGS has no control over other contractor’s review strategy. The recertification requirement is not currently part of the CGS medical review strategy, but will be later this summer. CGS encourages all providers to include the recertification estimate for any claims with dates of service on or after the implementation of CR 9119.

Access the full CGS Ask-the-Contractor (ACT) Questions and Answers here.

Information regarding CR 9189 is available in an article posted by the National Association of Home Care and Hospice (NAHC) here.


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  1. ameri - July 28, 2015

    More burden on HHA’s. Per NAHC’s guidance, we could add ““I certify that in my estimation continued services will be required for _______.”
    Where can we put this?? I am not sure where on the POC will be the best place to add it.

    • Deanna Loftus - July 28, 2015

      CMS did not provide instructions to reviewers on how or where this statement needed to be located.

      If you choose to utilize/update the existing certification statement/field locator 26 here is an example of what it could look like:
      field locator 26

      If you choose to not place the information in the existing certification statement/field locator 26, as long as the verbiage recommended by NAHC is utilized, it should be acceptable to place it anywhere on the document or receive as a verbal. The only consideration of using a location on the recertification form other than the existing certification statement/field locator 26, is educating physicians to make sure it is not overlooked.

    • Lisa Bivens - July 28, 2015

      During the most recent webinar concerning CR9119 hosted by CGS, it was clarified that Agencies may include the estimate on the plan of care and the physician signing it would meet the requirement. This was contrary to the original instruction that stated the physician would have to provide this information. This clarification was a result of the CMS Open Door Forum held on July 8th. Please advise if this is incorrect.

      • Deanna Loftus - July 28, 2015

        CGS posted an FAQ document last Friday as a follow-up to the webinar they held on June 24th. A link to the FAQ is included in the blog article. Questions 4, 16 and 33 reference the recertification requirement.

        Agencies must obtain the estimate from the physician and it is acceptable that it be an oral communication. While CMS did not provide instructions on how or where the estimate statement needs to be located, they did state in the CR “The contractor shall review for the certifying physician statement which must indicate the continuing need for services and estimate how much longer the services will be required.”

        The National Association of Homecare (NAHC) is recommending agencies either incorporate a statement within the existing certification statement for recertification or include a separate statement in the medical documentation where it is obvious to the reviewer, such as on the plan of care. One way agencies could ensure compliance with this requirement, would be to receive the estimate from the physician via an oral communication and then include that estimate within the existing certification statement for recertification for the physician to sign.

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