CMS Clarifies Documentation Rules
HHAs May Provide Documentation for Inclusion in the Physician Record
Tuesday, March 31, 2015
by: Visiting Nurse Associations of America

Section: Breaking News

The Centers for Medicare and Medicaid Services (CMS) issued a policy clarification on the required documentation to support certification for home health services, which includes the face-to-face encounter, homebound status, and need for skilled services. CMS acknowledged that it provided inaccurate information on its last call related to Medicare documentation and the draft standardized templates. CMS clarified that it will allow HHAs to provide documentation for incorporation into the patient's record, which can then be used to substantiate that the individual is eligible for home health services. The physician must review and sign off on any documentation provided by the HHA. CMS intends to release additional guidance regarding the review of home health claims. This clarification aligns with VNAA's request to CMS to allow HHAs to provide evidence that an individual meets the home health eligibility criteria. CMS posted the following clarification on its website :

"In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services. Per 42CFR 424.22 (a) and (c), the patient's medical record must support the certification of eligibility and documentation in the patient's medical record shall be used as a basis for certification of home health eligibility. Therefore, reviewers will consider HHA documentation if it is incorporated into the patient's medical record and signed off by the certifying physician. More guidance will follow regarding the review of home health claims shortly. CMS apologizes for the confusion."

CMS' next and final call on the documentation templates will be held on Tuesday April 28, 2015 at 1:30 p.m. ET. CMS has combined the two previous scheduled calls for April 8, 2015 and May 6, 2015 into this final call. An updated version of the draft templates will be posted prior to the Open Door Forum.

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