The American Hospital Association has objected to CMS proposals to create new procedures for auditing home health providers.
One of the proposed changes — which were included in the agency's proposed rule for the Medicare home health prospective payment system for calendar year 2015 — would base home health medical necessity audits "only the medical record for the patient from the certifying physician or the acute/post-acute facility." In a comment letter to CMS, AHA Executive Vice President Rick Pollack writes that "Under this proposal, if the certifying physician's record lacks sufficient documentation of eligibility for Medicare HH services, payment would not be rendered to the HH agency. Rather, audits of HH medical necessity should be based on the documentation found in HH agencies' medical records."
Similarly, Mr. Pollack writes the AHA opposes another proposal that would base payment for physician claims for certification and re-certification of home health eligibility on the status of the home health provider claim: "Any audit of physician services should be based on the claims and medical records of that physician; therefore, we urge CMS to withdraw this proposal, as well."
Among other comments, the AHA expressed support for CMS' proposal to eliminate the face-to-face encounter narrative requirement, under which providers must write a brief description of the patient's clinical condition and how that condition supports homebound status and the need for skilled services. The PPACA mandates that certifying physicians or allowed non-physician providers must have a face-to-face encounter with a patient before certifying eligibility for the Medicare home health benefit. The AHA has suggested that CMS consider only requiring a new face-to-face encounter for home health treatment concerning a new condition in the same 60-day period.
The AHA also supports CMS' proposal to base the home health therapy reassessment schedule on calendar days instead of therapy visits, although the AHA has recommended a longer assessment interval.