Tuesday, January 11, 2011
*****Special Announcement: CMS Delays Enforcement of Home HEalth Face-to-Face Requirement*****
The Centers for Medicare & Medicaid Services (CMS) has agreed to delay enforcement of the home health face-to-face encounter requirement until April 1, 2011, though the January 1, 2011, implementation date remains in place. In November, CMS issued a final rule implementing the Affordable Care Act provision that requires face-to-face encounters between home healthcare patients and their physicians to initiate (SOC)Medicare coverage of home healthcare. CMS stated that while implementation of F2F would begin as planned on January 1, 2011, enforcement will not take place until after a three-month transition period. CMS has made it clear that the the three-month transition to enforcement of this face-to-face requirement will not be further extended.
Monday, January 10, 2011
Home Health Billing Dispute Resolution Requests
Good Afternoon MFS bloggers,
PGBA recently published an article regarding the fact that providers sometimes experience situations where they are unable to resolve a billing dispute with another provider either due to overlapping dates of service or sequential billing.
Home health providers should ensure that a patient's Medicare eligibility records are reviewed before the patient is admitted. If the patient's Medicare eligibility records reflect that care is or was being provided by another provider, and the records do not reflect that the previous provider has finalized their billing, the receiving provider is responsible for contacting the existing/previous provider to request that they complete their billing.
What should the agency do in case there is a dispute?
Should a dispute arise, both agencies are required under Medicare regulations to make an attempt to resolve the issue between them. If the agencies are unable to resolve the dispute, Palmetto GBA may be contacted for assistance.
Palmetto GBA will work with both agencies to settle the dispute. Providers seeking assistance from Palmetto GBA to resolve a billing dispute should complete the Billing Dispute Resolution Request Form found at the PGBA-RHHI website (forms.) All information on the form is required to assist the provider.
Note: Providers are not required to use the form, but all requests must include the elements contained in the form. If the form is incomplete or the written request does not include all the required information, the request will be returned to the provider. Providers should also note that the request to settle a billing dispute must pertain to claims that are within the timely filing requirements unless the situation falls within the exceptions to grant an extension to the timely filing requirement. Please refer to the Timely Filing Guidelines Job Aid for additional information on the timely filing requirements.
Upon receipt of the completed form or a written request that includes all the required information, Palmetto GBA will take the necessary steps to assist the provider with resolving the situation.
PGBA recently published an article regarding the fact that providers sometimes experience situations where they are unable to resolve a billing dispute with another provider either due to overlapping dates of service or sequential billing.
Home health providers should ensure that a patient's Medicare eligibility records are reviewed before the patient is admitted. If the patient's Medicare eligibility records reflect that care is or was being provided by another provider, and the records do not reflect that the previous provider has finalized their billing, the receiving provider is responsible for contacting the existing/previous provider to request that they complete their billing.
What should the agency do in case there is a dispute?
Should a dispute arise, both agencies are required under Medicare regulations to make an attempt to resolve the issue between them. If the agencies are unable to resolve the dispute, Palmetto GBA may be contacted for assistance.
Palmetto GBA will work with both agencies to settle the dispute. Providers seeking assistance from Palmetto GBA to resolve a billing dispute should complete the Billing Dispute Resolution Request Form found at the PGBA-RHHI website (forms.) All information on the form is required to assist the provider.
Note: Providers are not required to use the form, but all requests must include the elements contained in the form. If the form is incomplete or the written request does not include all the required information, the request will be returned to the provider. Providers should also note that the request to settle a billing dispute must pertain to claims that are within the timely filing requirements unless the situation falls within the exceptions to grant an extension to the timely filing requirement. Please refer to the Timely Filing Guidelines Job Aid for additional information on the timely filing requirements.
Upon receipt of the completed form or a written request that includes all the required information, Palmetto GBA will take the necessary steps to assist the provider with resolving the situation.
Tuesday, January 4, 2011
CMS Clarifies POC Physician Signature Requirements
Happy 2011 to all MFS Bloggers,
CMS recently clarified its position with regard to physician's signing and dating Plans of Care. I have seen many POC denial determinations and post-payment audits incorrectly assessed by various Intermediaries based upon this policy.
Palmetto GBA published clarification due to recently received clarifications from the Centers for Medicare & Medicaid Services (CMS) in reference to physician signatures with stamped dates. CMS has clarified that physicians must sign and date home health plans of care, verbal orders and certifications. This changes Palmetto GBA's long standing policy of accepting a date stamp or facsimile date as proof of timeliness in lieu of a physician dating his/her signature. This change is effective for all documents signed on or after January 1, 2011.
Based on the following CMS references, failure to meet these requirements may result in full or partial denial of services.
- CMS Internet Only Manuals (IOMs), Publication 100-01, Medicare General Information, Eligibility and Entitlement Manual, Chapter 4, Section 30.1 states that "the attending physician signs and dates the POC/certification prior to the claim being submitted for payment."
- This manual requirement is also addressed in 42 CFR 424.22 (D)2 effective January 1, 2011, and states that "the certification of need for home health services must be obtained at the time the plan of care is established or as soon thereafter as possible and must be signed and dated by the physician who establishes the plan.' The instructions for re-certifications are found in this same Part and restates that it 'must be signed and dated by the physician who reviews the plan of care."
CMS recently clarified its position with regard to physician's signing and dating Plans of Care. I have seen many POC denial determinations and post-payment audits incorrectly assessed by various Intermediaries based upon this policy.
Palmetto GBA published clarification due to recently received clarifications from the Centers for Medicare & Medicaid Services (CMS) in reference to physician signatures with stamped dates. CMS has clarified that physicians must sign and date home health plans of care, verbal orders and certifications. This changes Palmetto GBA's long standing policy of accepting a date stamp or facsimile date as proof of timeliness in lieu of a physician dating his/her signature. This change is effective for all documents signed on or after January 1, 2011.
Based on the following CMS references, failure to meet these requirements may result in full or partial denial of services.
- CMS Internet Only Manuals (IOMs), Publication 100-01, Medicare General Information, Eligibility and Entitlement Manual, Chapter 4, Section 30.1 states that "the attending physician signs and dates the POC/certification prior to the claim being submitted for payment."
- This manual requirement is also addressed in 42 CFR 424.22 (D)2 effective January 1, 2011, and states that "the certification of need for home health services must be obtained at the time the plan of care is established or as soon thereafter as possible and must be signed and dated by the physician who establishes the plan.' The instructions for re-certifications are found in this same Part and restates that it 'must be signed and dated by the physician who reviews the plan of care."
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