Updated Transmittals on Face-to-Face and Therapy Reassessments

The Centers for Medicare and Medicaid Services (CMS) posted two transmittals that update sections of the Medicare Home Health manual to reflect changes as a result of the CY 2015 HH PPS final rule that was published on Nov. 6, 2014. Please note if you opt to print the transmittals do so in color so you can see the revisions in red.

The first transmittal, #91, makes changes as they relate to the requirements for physician certification and recertification of patient eligibility for Medicare home health services. There are four areas that are revised:

4/30 - Certification and Recertification by Physicians for Home Health Services;
4/30.1 - Content of the Physician's Certification;
4/30.2 - Method and Disposition of Certification for Home Health Services; and
4/30.3 - Recertification for Home Health Services.

This follows the three changes to the Face-to-Face (F2F) encounter requirements for episodes beginning on or after Jan. 1, 2015. As we previously reported they include:

First, CMS has eliminated the narrative requirement. The certifying physician is still required to certify that a F2F patient encounter occurred and document the date of the encounter as part of the certification of eligibility.
Second, if an HHA claim is denied, the corresponding physician claim for certifying/re-certifying patient eligibility for Medicare-covered home health services is considered non-covered as well because there is no longer a corresponding claim for Medicare covered home health services.
Third, CMS clarified that a F2F encounter is required for certifications, rather than initial episodes; and that a certification (versus a re-certification) is generally considered to be any time a new start of care assessment is completed to initiate care.

The second transmittal, #207, again makes changes as they relate to the requirements for physician certification and recertification of patient eligibility for Medicare home health services and also updates the timeframe required for therapy functional reassessments. For therapy reasessments CMS has eliminated the 13th and 19th visit therapy reassessment requirements. For the same time period, episodes beginning on or after January 1, 2015; at least every 30 calendar days a qualified therapist (instead of an assistant) must provide the needed therapy service and functionally reassess the patient.

This policy change is to lessen home health agencies challenge with counting visits.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871