Recertification statement

The following statement is from a recent article regarding pre-claim
reviews and what agencies should review in documentation to reduce
errors.

"For re-certifications, be aware that the re-certification statement on
the projected length of time the patient will need home care will need
to be submitted separately from the Plan of Care."

Can someone direct me as to where this regulation can be found? We
currently complete a 60 day summary with the finite end of care but it
is incorporated in the Plan of Care - not separately.





Mary Dominic, RN

Qualty Assurance Manager

mvi HomeCare, Inc.

4891 Belmont Ave.

Youngstown, Ohio 44505

330-759-9487

Comments

  • Mary,
    We had our education call for Probe and Educate on Monday and our educator told us that it could be on the plan of care and did not need to be separate. Very confusing depending on the information source.

    Melody Ford RN BSN CRNI
    Director of Clinical Services, Owner
    ABF Home Health Services, LLC
    198 S. Main Suite 1
    Mount Clemens, MI 48043
    P: 586-477-1402
    F: 586-477-1413
    www.abfhomehealth.com

  • edited May 2017
    The regulation on the recert statement is at 42 CFR 424.22(b)(2) - but it does not specify where or how that is to be done. I went to Medicare Benefit manual (102) - old HIM-11- Chapter 7 for home health & at Section 30.5.2 on Recertification it states:

    "Under HH PPS the plan of care must be reviewed and signed by the physician every 60 days unless one of the following occurs:" (Beneficiary transfer or discharge & return to HHA during 60 day episode)..."The physician must include an estimate of how much longer the skilled services will be required and must certify that: ..."

    So - nowhere does it specifically state that the narrative needs to be on plan of care or another document. This language makes it sound that it can be on POC however. And I suggest that is the best place for it...and it should be right above the signature line.

    You can access the manual at: https://www.cms.gov/regulations-and-guidance/guidance/manuals/internet-only-manuals-ioms.html

    Liz Pearson
    Pearson & Bernard PSC
    178 Barnwood Dr.
    Edgewood, Ky 41017
    859-655-3700 (w) 859-655-3703 (f)

  • This is from one of my old emails back and forth with CMS on this. I hope it helps.

    in order to meet the recertification requirement that “The recertification statement must indicate the continuing need for services and estimate how much longer the services will be required.”(see424.22(b)(2), below).

    Below is 424.22(b) (Note: We did not change 424.22(b)(2) in the CY 2015 rule. This is a ”long standing requirement” for recertifications):

    (b) Recertification—(1) Timing and signature of recertification. Recertification is required at least every 60 days when there is a need for continuous home health care after an initial 60-day episode. Recertification should occur at the time the plan of care is reviewed, and must be signed and dated by the physician who reviews the plan of care. Recertification is required at least every 60 days unless there is a—
    (i) Beneficiary elected transfer; or
    (ii) Discharge with goals met and/or no expectation of a return to home health care.
    (2) Content and basis of recertification. The recertification statement must indicate the continuing need for services and estimate how much longer the services will be required. Need for occupational therapy may be the basis for continuing services that were initiated because the individual needed skilled nursing care or physical therapy or speech therapy. If a patient's underlying condition or complication requires a registered nurse to ensure that essential non-skilled care is achieving its purpose, and necessitates a registered nurse be involved in the development, management, and evaluation of a patient's care plan, the physician will include a brief narrative describing the clinical justification of this need. If the narrative is part of the recertification form, then the narrative must be located immediately prior to the physician's signature. If the narrative exists as an addendum to the recertification form, in addition to the physician's signature on the recertification form, the physician must sign immediately following the narrative in the addendum.

    As such, the changes that we recently made in the manual were to be more painfully obvious as to what is required for the patient to continue receiving home health services (i.e. required for recertifications), by mirroring what the reg text has always said. Here is what the Manual now says:

    The physician must include an estimate of how much longer the skilled services will be required and must certify (attest) that:
    1. The home health services are or were needed because the patient is or was confined to the home as defined in §30.1;
    2. The patient needs or needed skilled nursing services on an intermittent basis (other than solely venipuncture for the purposes of obtaining a blood sample), or physical therapy, or speech-language pathology services; or continues to need occupational therapy after the need for skilled nursing care, physical therapy, or speech-language pathology services ceased. Where a patient’s sole skilled service need is for skilled oversight of unskilled services (management and evaluation of the care plan as defined in §40.1.2.2), the physician must include a brief narrative describing the clinical justification of this need as part of the recertification, or as a signed addendum to the recertification;
    3. A plan of care has been established and is periodically reviewed by a physician; and
    4. The services are or were furnished while the patient is or was under the care of a physician.

    The regulations have always implied that the patient had to continue meeting eligibly to be re-certified, which is what the statute says (see below):

    Sec. 1814. [42 U.S.C. 1395f] (a) Except as provided in subsections (d) and (g) and in section 1876, payment for services furnished an individual may be made only to providers of services which are eligible therefor under section 1866 and only if—

    (1) written request, signed by such individual, except in cases in which the Secretary finds it impracticable for the individual to do so, is filed for such payment in such form, in such manner, and by such person or persons as the Secretary may by regulation prescribe, no later than the close of the

    (2) a physician, or, in the case of services described in subparagraph (B), a physician, or a nurse practitioner, a clinical nurse specialist, or a physician assistant (as those terms are defined in section 1861(aa)(5)) who does not have a direct or indirect employment relationship with the facility but is working in collaboration with a physician, certifies (and recertifies, where such services are furnished over a period of time, in such cases, with such frequency, and accompanied by such supporting material, appropriate to the case involved, as may be provided by regulations, except that the first of such recertifications shall be required in each case of inpatient hospital services not later than the 20th day of such period) that—

    (A) in the case of inpatient psychiatric hospital services, such services are or were required to be given on an inpatient basis, by or under the supervision of a physician, for the psychiatric treatment of an individual; and (i) such treatment can or could reasonably be expected to improve the condition for which such treatment is or was necessary or (ii) inpatient diagnostic study is or was medically required and such services are or were necessary for such purposes;

    (B) in the case of post-hospital extended care services, such services are or were required to be given because the individual needs or needed on a daily basis skilled nursing care (provided directly by or requiring the supervision of skilled nursing personnel) or other skilled rehabilitation services, which as a practical matter can only be provided in a skilled nursing facility on an inpatient basis, for any of the conditions with respect to which he was receiving inpatient hospital services (or services which would constitute inpatient hospital services if the institution met the requirements of paragraphs (6) and (9) of section 1861(e)) prior to transfer to the skilled nursing facility or for a condition requiring such extended care services which arose after such transfer and while he was still in the facility for treatment of the condition or conditions for which he was receiving such inpatient hospital services;

    (C) in the case of home health services, such services are or were required because the individual is or was confined to his home (except when receiving items and services referred to in section 1861(m)(7)) and needs or needed skilled nursing care (other than solely venipuncture for the purpose of obtaining a blood sample) on an intermittent basis or physical or speech therapy or, in the case of an individual who has been furnished home health services based on such a need and who no longer has such a need for such care or therapy, continues or continued to need occupational therapy; a plan for furnishing such services to such individual has been established and is periodically reviewed by a physician; such services are or were furnished while the individual was under the care of a physician , and, in the case of a certification made by a physician after January 1, 2010, prior to making such certification the physician must document that the physician himself or herself , or a nurse practitioner or clinical nurse specialist (as those terms are defined in section 1861(aa)(5)) who is working in collaboration with the physician in accordance with State law, or a certified nurse-midwife (as defined in section 1861(gg)) as authorized by State law, or a physician assistant (as defined in section 1861(aa)(5)) under the supervision of the physician, has had a face-to-face encounter (including through use of telehealth, subject to the requirements in section 1834(m), and other than with respect to encounters that are incident to services involved) with the individual within a reasonable timeframe as determined by the Secretary; or

    I/we have no idea how OFM has enforced this in the past. From a payment policy perspective, we are saying that the recertification needs to contain statements that attest to the continuing need for services and estimate how much longer the services will be required. From our perspective, whether those statements were put on the recertification by the HHA or the physician, is of no real significance. Historically, it has been viewed that the HHA is the eyes and ears of the physician while HH services are being provided to a home health patient. As such, physicians rely on the HHA for such estimates as it is the HHA that is actually seeing the patient. Through the recertification, the physician is simply attesting to the need for skilled care, estimating how much longer those services will be needed, that the that the patient continues to be eligible for the benefit, etc. etc.. In so far as the re-cert “de facto” meaning the patient needs HH services for at least another 60-days, we believe that OFM would need to confirm that interpretation.

    Bottom Line: We (payment policy) believe it would be fine to have a statement written by the HHA, in which the physician is attesting to, so long as it is part of the recertification, and all the other certification/recertification requirements are met. You may want to reach out to OFM on some of the other aspects noted above.





    > On Sep 21, 2016, at 12:28 PM, Elizabeth Pearson wrote:
    >
    > The regulation on the recert statement is at 42 CFR 424.22(b)(2) – but it does not specify where or how that is to be done. I went to Medicare Benefit manual (102) – old HIM-11- Chapter 7 for home health & at Section 30.5.2 on Recertification it states:
    >
    > “Under HH PPS the plan of care must be reviewed and signed by the physician every 60 days unless one of the following occurs:” (Beneficiary transfer or discharge & return to HHA during 60 day episode)…”The physician must include an estimate of how much longer the skilled services will be required and must certify that: …”
    >
    > So – nowhere does it specifically state that the narrative needs to be on plan of care or another document. This language makes it sound that it can be on POC however. And I suggest that is the best place for it…and it should be right above the signature line.
    >
    > You can access the manual at: https://www.cms.gov/regulations-and-guidance/guidance/manuals/internet-only-manuals-ioms.html
    >
    > Liz Pearson
    > Pearson & Bernard PSC
    > 178 Barnwood Dr.
    > Edgewood, Ky 41017
    > 859-655-3700 (w) 859-655-3703 (f)
    >
    > Confidentiality Note: The information contained in this e-mail message is legally privileged and confidential information and is intended only for the use of the individual or entity named herein. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this e-mail is strictly prohibited.
    >
    > If you have received this e-mail in error, please immediately notify us by replying to this message and delete the e-mail from your computer. Thank you.
    >
    > From: Melody Ford [mailto:mford@abfhomehealth.com ]
    > Sent: Wednesday, September 21, 2016 12:26 PM
    > To: Multiple recipients of list MYHOMEHEALTH-L
    > Subject: RE:[myhomehealth-l] Recertification statement
    >
    > Mary,
    > We had our education call for Probe and Educate on Monday and our educator told us that it could be on the plan of care and did not need to be separate. Very confusing depending on the information source.
    >
    > Melody Ford RN BSN CRNI
    > Director of Clinical Services, Owner
    > ABF Home Health Services, LLC
    > 198 S. Main Suite 1
    > Mount Clemens, MI 48043
    > P: 586-477-1402
    > F: 586-477-1413
    > www.abfhomehealth.com
    >
    >
    > Confidentiality Notice: The information in this email, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and legally privileged information. If you are not the intended recipient, any disclosure, copying, distribution or use of the contents of this information in any manner is strictly prohibited and may be unlawful. If you receive this message in error, or are not the named recipient(s), please notify the sender by reply email, delete this email from your computer, and destroy copies of the form immediately.
    >
    >
    > From: Mary Dominic [mailto:MDominic@mvihomecare.com ]
    > Sent: Wednesday, September 21, 2016 12:21 PM
    > To: Multiple recipients of list MYHOMEHEALTH-L
    > Subject: [myhomehealth-l] Recertification statement
    >
    > The following statement is from a recent article regarding pre-claim reviews and what agencies should review in documentation to reduce errors.
    > “For re-certifications, be aware that the re-certification statement on the projected length of time the patient will need home care will need to be submitted separately from the Plan of Care.”
    > Can someone direct me as to where this regulation can be found? We currently complete a 60 day summary with the finite end of care but it is incorporated in the Plan of Care – not separately.
    >
    >
    > Mary Dominic, RN
    > Qualty Assurance Manager
    > mvi HomeCare, Inc.
    > 4891 Belmont Ave.
    > Youngstown, Ohio 44505
    > 330-759-9487
    >
    > ---
    > This list is an exclusive service of DecisionHealth (http://www.decisionhealth.com ), publisher of Home Health Line. To access the web interface, go to http://www.decisionhealth.com/myhomehealth-l and enter your e-mail address. Click on the My Account tab and then the Advanced tab to set or change your password. Click on the Essentials tab and Membership Type to set the way you want to access list messages. To read messages on the web interface only, set Membership Type to ?no mail.? To see the archive of past messages, click on the Messages tab and the Show More button. To view the chat forum, click on the Conference tab. To unsubscribe, click on the My Forums tab.
    > ---
    > This list is an exclusive service of DecisionHealth (http://www.decisionhealth.com ), publisher of Home Health Line. To access the web interface, go to http://www.decisionhealth.com/myhomehealth-l and enter your e-mail address. Click on the My Account tab and then the Advanced tab to set or change your password. Click on the Essentials tab and Membership Type to set the way you want to access list messages. To read messages on the web interface only, set Membership Type to ?no mail.? To see the archive of past messages, click on the Messages tab and the Show More button. To view the chat forum, click on the Conference tab. To unsubscribe, click on the My Forums tab.
    > ---
    > This list is an exclusive service of DecisionHealth (http://www.decisionhealth.com ), publisher of Home Health Line. To access the web interface, go to http://www.decisionhealth.com/myhomehealth-l and enter your e-mail address. Click on the My Account tab and then the Advanced tab to set or change your password. Click on the Essentials tab and Membership Type to set the way you want to access list messages. To read messages on the web interface only, set Membership Type to “no mail.” To see the archive of past messages, click on the Messages tab and the Show More button. To view the chat forum, click on the Conference tab. To unsubscribe, click on the My Forums tab.

    Michael McGowan, MBA/HCA
    Senior Consultant/Expert Witness
    Medicare Appeals Development,LLC
    Direct 916-343-1164
    Michael@madappeals.com
    www.madappeals.com
    Time is valuable and creative thought is even more so. Don’t undervalue either.
    “Good planning and hard work lead to prosperity, but hasty shortcuts lead to poverty.”Proverbs 21:5 (NLT)
    This communication constitutes an electronic communication within the meaning of the Electronic Communications Privacy Act, 18 USC 2510, and its disclosure is strictly limited to the recipient intended by the sender of this message. This communication may contain confidential and privileged material for the sole use of the intended recipient and receipt by anyone other than the intended recipient does not constitute a loss of the confidential or privileged nature of the communications. Any review or distribution by others is strictly prohibited. If you are not the intended recipient please contact the sender by return electronic mail and delete all copies of this communication.
Sign In or Register to comment.