Eye to Eye on Face-to-Face Lunch and Learn Webinar June 17, 2015 Home Health Coverage Resources CMS “Medicare Benefit Policy Manual” (CMS Pub. 100-02) Chapter 7; Home Health http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/bp102c07.pdf Medicare Benefit Policy Manual Chapter 7 - Home Health Services Table of Contents (Rev. 208, 05-11-15) 2 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 1 Home Health Coverage Resources CGS “Home Health Coverage Guidelines” Web page http://www.cgsmedicare.com/hhh/coverage/Home_Health_Cove rage_Guidelines.html 3 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 4 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 2 CR 9119 “Manual Updates to Clarify Requirements for Physician Certification and Recertification of Patient Eligibility for Home Health Services” http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNMattersArticles/downloads/MM9119.pdf 5 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 CMS Manual System; Pub 100-01 Medicare General Information, Eligibility, and Entitlement; Change Request 9119 http://www.cms.gov/Regulations-andGuidance/Guidance/Transmittals/Downloads/R92GI.pdf 6 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 3 CR 9119 CMS Manual System; Pub 100-02 Medicare Benefit Policy; Change Request 9119 https://www.cms.gov/Regulations-andGuidance/Guidance/Transmittals/Downloads/R207BP.pdf 7 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 Three Changes to Face-to-Face Requirements 1. CMS eliminated the narrative requirements 2. If HHA claim is denied, the certifying/recertifying physician claim is noncovered. • Because there would be no corresponding claim 3. Clarification that the face-to-face (FTF) encounter is required for certifications; rather the initial episodes • New start of care OASIS assessment completed 8 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 4 CR 9119 Three Changes to Face-to-Face Requirements 1. CMS eliminated the narrative requirements 2. If HHA claim is denied, the certifying/recertifying physician claim is noncovered. • Because there would be no corresponding claim 3. Clarification that the face-to-face (FTF) encounter is required for certifications; rather the initial episodes • New start of care OASIS assessment completed 9 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 Three Changes to Face-to-Face Requirements 1. CMS eliminated the narrative requirements 2. If HHA claim is denied, the certifying/recertifying physician claim is noncovered. • Because there would be no corresponding claim 3. Clarification that the face-to-face (FTF) encounter is required for certifications; rather the initial episodes • New FTF for every completed start of care OASIS assessment 10 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 5 CR 9119: Supporting Documentation Per 100-02 Ch. 7 section 30.5.1.2, for SOC effective January 1, 2015, documentation in certifying physician’s medical record and/or acute/post-acute care facility’s medical record: Will be used as basis for patient’s home health eligibility Must contain information to justify the referral for home health services including: • Need for skilled services; and • Homebound status 11 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119: Supporting Documentation Per 100-02 Ch. 7 section 30.5.1.2, for SOC effective January 1, 2015, documentation in certifying physician’s medical record and/or acute/post-acute care facility’s medical record: Must be provided to home health agency when requested 12 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 6 CR 9119: Supporting Documentation • Change Request 9112, “Clarification of Ordering and Certifying Documentation Maintenance Requirements”, http://www.cms.gov/Outreach-and-Education/Medicare-LearningNetwork-MLN/MLNMattersArticles/Downloads/MM9112.pdf 13 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119: Supporting Documentation Per 100-02 Ch. 7 section 30.5.1.2, certifying physician and/or acute/post-acute facility medical record (if the patient was directly admitted to home health) for the patient must contain the actual clinical note for the FTF encounter visit that demonstrates that the encounter: Occurred within required timeframe; Was related to primary reason patient requires home health services; and Was performed by an allowed provider type. 14 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 7 CR 9119: Supporting Documentation Information from home health associations (HHAs), such as initial and/or comprehensive assessment of the patient, can be incorporated into certifying physician’s medical record for the patient and used to support patient’s homebound status and need for skilled care HHA’s documentation must be signed/dated by certifying physician to indicate acceptance of documentation into their medical records Physician’s dated signature must be on/before certification date 15 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119: Supporting Documentation Information from the HHA incorporated into the physician’s medical record must not conflict with other medical record entries in certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient • Information submitted & incorporated from HHAs must be received timely to ensure certifying physician has all relevant information when making decision to certify/recertify the patient • The certifying physician (or allowed non-physician provider) must have a face-to-face encounter with the beneficiary before they certify the beneficiary's eligibility 16 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 8 CR 9119: Physician Recertification New requirement: The physician must include an estimate of how much longer skilled services will be required Note: A recertification that does not include this information may result in a claim denial 17 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 Two most common scenarios: Scenario #1 Patient discharged from acute/post-acute facility directly to home health services The hospitalist is seeing patient while in the hospital Scenario #2 Patient admitted to home health, not resulting from acute/post-acute discharge Community physician is seeing patient in physician’s office with no hospitalization 18 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 9 CR 9119 Scenario #1: Patient discharged from acute/post-acute facility directly to home health services Hospitalist sees patient & performs FTF encounter Community physician will follow patient after discharge and certifies HH services • HH criteria requires patient to be under care of physician • Certifying physician must document the date of the FTF encounter NOTE: If hospitalist performs FTF encounter and also certifies patient for home health, the hospitalist must identify the community physician who will follow the patient 19 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CR 9119 Scenario #2: Patient admitted to home health, not resulting from acute/post-acute discharge Community physician has in-person visit (FTF) with patient 90 days before or 30 days after 1st HHA visit (and the in-person visit is related to the reason for home health services) Documents FTF encounter in medical record, and certifies patient’s eligibility for home health 20 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 10 MLN Matters® SE1436 “Certifying Patients for the Medicare Home Health Benefit” SE1436. Important information plus document examples http://www.cms.gov/Outreach-and-Education/Medicare-LearningNetwork-MLN/MLNMattersArticles/downloads/SE1436.pdf 21 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. MLN Matters® SE1436 22 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 11 MLN Matters® SE1436 23 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Face-to-Face Documents To be eligible for Medicare home health services, a patient must have Medicare Part A and/or Part B and: 24 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 1. Be confined to the home; 2. Need skilled services; 3. Be under the care of a physician; 4. Receive services under a plan of care established and reviewed by a physician; and 5. Had a face-to-face encounter performed by: Certifying physician (must be Medicare enrolled) Non-physician practitioner (NPP) in collaboration with the certifying physician Physician who cared for the patient in an acute/postacute facility during a recent stay and has privileges in that facility © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 12 Face-to-Face Documents Information from the HHA can be incorporated into the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient. Information from the HHA must be corroborated by other medical record entries and align with the time period in which services were rendered. The certifying physician must review and sign off on anything incorporated into the patient’s medical record that is used to support the certification of patient eligibility. 25 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. When? Certifying physician must document FTF took place within 90 days prior to start of care (SOC), or 30 days after SOC Reminder: FTF must be related to primary reason for home health admission Exceptional circumstance: Patient death before FTF can be performed 26 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 13 Face-to-Face The physician who cared for the patient in an acute or post-acute facility may choose to use documentation from the patient’s medical record, (such as a discharge summary) to inform the certifying physician of the clinical findings from the face-to-face encounter. IF The compiled documentation is reflective of the clinical findings of the face-to-face encounter AND Serves as that physician’s communication to the certifying physician 27 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Face-to-Face Signatures The document from the acute or post acute facility record Must be signed and dated by the certifying physician, Must indicate the certifying physician received the information from the physician who performed the face-to-face encounter, and Must show the certifying physician is using that documentation as his/her documentation of the face-to-face encounter 28 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 14 Documentation Does the documentation clearly answer “why home health and why now?” Reminder: Good documentation should address: Objective clinical evidence of patient’s individual need for care Progress or lack of progress Medical condition Functional losses 29 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Examples of FTF Documentation “Don’ts” Insufficient documentation – Miscellaneous The following may cause a claim to NOT BE PAID: Diagnoses/clinical findings on FTF not related to home care ordered Altered documentation without acceptable notations for changes FTF signed by Non Physician Practitioner (NPP) only No date of FTF encounter Not clearly titled as face-to-face encounter 30 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 15 FTF Documentation: Important Reminders FTF is requirement for Medicare payment Missing/incomplete documentation results in entire claim being denied As the billing entity, the home health agency’s (HHA’s) responsibilities include: Facilitating and coordinating between patient and physician to ensure FTF occurs timely Ensuring all FTF requirements are met Ensuring physician’s documentation is complete Delaying submission of claim until documentation complete 31 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Medical Necessity All services (even skilled) must be reasonable and medically necessary related to the patient’s condition. Does the documentation clearly answer “why home health and why now?” Reminder: Good documentation should address: Objective clinical evidence of patient’s individual need for care Progress or lack of progress Medical condition Functional losses Treatment goals Discharge planning 32 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 16 Medical Necessity Covers all disciplines Nursing Physical therapy Occupational therapy Speech language pathology 33 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Medical Necessity Additional information http://www.cgsmedicare.com/hhh/coverage/HH_Coverage_Guid elines/1E.html 34 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 17 Medical Necessity - “Do’s” Identify skilled service, and reason skilled service is necessary for beneficiary in objective terms Examples of good documentation: “Wound care completed per POC to left great toe. No s/s of infection, but patient remains at risk due to diabetic status.” “Range of motion (ROM) is tolerated to lower extremities. Unsafe to teach caregiver ROM due to displaced fracture.” 35 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Medical Necessity – “Do’s” Demonstrate medical necessity of skilled observation and assessment by documenting complexity of beneficiary’s condition and co-morbidities affecting outcomes. Examples of good documentation: “Lungs sound coarse throughout. Patient finished antibiotic therapy today for pneumonia, and seeing pulmonologist tomorrow for follow up to due to COPD and emphysema.” “Stasis wound on LLE continues to show 50% granulation and moderate serous drainage. Instructed patient on need to elevate legs and exercises related to peripheral vascular disease.” 36 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 18 Medical Necessity – “Don’ts” Medicare Benefit Policy Manual (CMS Pub. 100-02) Ch. 7, §40.1 and §40.2 lists requirements in order for a service to be covered by Medicare as “skilled.” The service must: Require the skills of a nurse or qualified therapist • Service is NOT skilled because it is performed by a nurse or qualified therapist • Service does NOT become unskilled because it is taught Be reasonable and necessary to treat patient’s illness or injury • Patient’s condition warrants the skilled care • MUST BE evident in documentation 37 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. No Response to ADR http://cgsmedicare.com/hhh/education/materials/pdf/ADR_QRT. pdf 38 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 19 No Response to ADR Quick resource tool Chart of how claim is processed List of how to check for ADRs using FISS Recommendations Checklist Preferred order of document submission 39 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. No Response to ADR Preferred order of document submission FISS Page 7 screen print Physician Face-to-Face documentation Plan of care with physician certification/recertifications Interim/verbal orders OASIS assessment Nursing visit notes Therapy visit notes including evaluations/re-evaluations Social work visit notes Aide visit notes Other relevant documentation 40 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 20 No Response to ADR http://www.cgsmedicare.com/hhh/medreview/adr_process.html 41 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. No Response to ADR Recommendations Clinicians review all documents prior to sending Providers may include an outline or a letter, but will not be considered actual documentation 42 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 21 Homebound Criteria http://www.cgsmedicare.com/hhh/coverage/HH_Coverage_Gu idelines/1C.html 43 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Homebound Criteria http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNMattersArticles/Downloads/MM8444.pdf 44 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 22 Homebound Criteria MLN Matters Home Health – Clarification to Benefit Policy Manual Language on “Confined to the Home” Definition Clarifies definition of patient being “confined to home” Reflects definition in Social Security Act (Section 1835(a)) Removes vague terms to ensure clear and specific definition Not a change in homebound definition 45 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Homebound Criteria Two criteria are used to determine homebound status Criteria-One: The patient must either: Because of illness or injury, need the aid of supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person in order to leave their place of residence. OR Have a condition such that leaving his or her home is medically contraindicated. 46 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 23 Homebound Criteria Two criteria are used to determine homebound status (continued) Criteria-Two: There must exist a normal inability to leave home AND Leaving home must require a considerable and taxing effort 47 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Homebound Criteria The patient may be considered homebound (confined to the home) if absences from the home are: infrequent; for periods of relatively short duration; for the need to receive health care treatment; for religious services; to attend adult daycare programs; or for other unique or infrequent events the patient may have more than one home • 48 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 vacation home, home of caregiver, seasonal home © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 24 Homebound Criteria Documentation must support homebound status throughout Beware of vague descriptions: “taxing effort”, “unable to leave home” Utilize objective, measurable language Examples of good documentation: “After ambulating 20 feet, patient has increased dyspnea and complains of back pain.” “Patient has unsteady gait, and must sit to rest after 20 feet of ambulation due to uncontrolled dyspnea.” 49 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Validity For a signature to be valid per Medicare requirements, the following criteria must be met Signatures are • Handwritten • Electronic • Stamped (under limited special circumstances) Signatures must be legible or identified Services that are provided or ordered must be authenticated by the ordering practitioner Medicare claim payment will be impacted if signatures are not valid 50 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 25 Signatures: Handwritten http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNMattersArticles/downloads/MM6698.pdf 51 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Handwritten The physician must hand date his hand written signature. If it is not hand dated, the claim will be fully denied Unable to determine if the signature was prior to billing Medicare Electronic signatures may appear to be handwritten. Submit electronic signature policy with documentation 52 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 26 Signatures: Electronic Computerized (electronic) patient records may use electronic signatures All electronic signatures must be properly authenticated and dated Authentication must include signatures, written initials, or a secure computer entry by a unique identifier of the author who reviewed and approved the entry 53 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Electronic Systems and software products must contain protections against unauthorized modifications Administrative safeguards must be in place to correspond to laws and standards Authenticity of the information being attested to is the responsibility of the provider and the individual whose signature is electronically presented Recommend the provider includes their electronic signature policy when submitting documentation in response to an additional development request (ADR) 54 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 27 Signatures: Missing If a signature is missing from an order, the order shall NOT be included in the review of the claim If a signature is missing from any other medical documentation, a signature attestation statement from the author of the document may be accepted 55 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Attestation Statement Attestation statements are not valid Where there is no associated medical record entry If from someone other than the author of the medical record entry in question Even if two individuals are in the same group, one may not sign for the other in medical record entries or attestation statements 56 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 28 Signatures: Submission Signature logs and attestations are encouraged to be included with documentation in the original submission Avoids delays or potential denials in the completion of the review 57 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Resources http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNMattersArticles/Downloads/SE1419.pdf 58 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 29 Signatures: Resources http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNProducts/downloads/Signature_Requirements_Fact _Sheet_ICN905364.pdf Medicare Program Integrity Manual; Pub. 100-08; Chapter 3 (3.3.2.4) – Verifying Potential Errors and Taking Corrective Actions http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/Downloads/pim83c03.pdf 59 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Signatures: Resources http://www.cms.gov/Outreach-and-Education/MedicareLearning-NetworkMLN/MLNProducts/downloads/Signature_Requirements_Fact _Sheet_ICN905364.pdf 60 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 30 CGS Home Health Denial Fact Sheets http://www.cgsmedicare.com/hhh/education/materials/HH_QR T.html 61 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. CGS Home Health Denial Fact Sheets 5HHBD – Homebound Status http://www.cgsmedicare.com/hhh/education/materials/pdf/hh _5hhbd_factsheet.pdf 62 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 31 CGS Home Health Denial Fact Sheets 5HMED – Medical Necessity http://www.cgsmedicare.com/hhh/education/materials/pdf/HH _5HMED_FactSheet.pdf 63 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Questions? CGS Provider Contact Center 1-877-299-4500 (Option 1) 64 CGS Administrators, LLC Eye to Eye on Face‐to‐Face Webinar June 17, 2015 June 15, 2015 © 2015 Copyright, CGS Administrators, LLC. Disclaimer: This resource is not a legal document. Any regulations, policies, and/or guidelines cited in this publication are subject to change without notice. Although every reasonable effort has been made to assure accurate information, responsibility for correct claims submission lies with the provider of services. Current Medicare regulations can be found on the CMS Web site, www.cms.gov Reproduction of this material for profit is prohibited. CPT codes, related data © 2015 AMA. ICD‐9‐CM codes, descriptors © 2015 32