Estimation of Duration of Services No Longer Required
On March 22, 2019 Medicare updated the Medicare Benefit Policy Manual to clarify the home health plan of care requirements for payment as a result of the recent changes to the home health plan of care requirements in the Medicare Conditions of Participation (CoPs) finalized in the January 13, 2017 Conditions of Participation for Home Health Agencies final rule (82 FR 4504).
Update to Re-Certification Requirements
The Code of Federal Regulations (CFR) at 42 CFR 424.22(b)(2) requires the certifying physician to include a statement that:
1) Indicates the continuing need for services; and
2) Estimates how much longer the beneficiary will require home health services.
CMS finalized a change to these physician recertification requirements in the 2019 Home Health final rule. Specifically, this rule eliminates the requirement that the certifying physician estimates how much longer the patient will require skilled care, when recertifying the patient for home health care. This change is effective for recertifications made on, and after January 1, 2019. All other recertification requirements (see Home Health CoP Section 424.22(b)(2)) remain unchanged.
Clarification of Home Health Plan of Care Requirements for Payment
The Home Health Conditions of Participation at 42 CFR 484.60(a) list the content requirements for the home health plan of care. Changes to these content requirements were finalized in the January 13, 2017 Home Health Conditions of Participation final rule (82 FR 4504) and became effective January 13, 2018.
CMS is clarifying that for HHA services to be covered:
- the individualized plan of care must specify the services necessary to meet the patient-specific needs identified in the comprehensive assessment
- the plan of care must include the identification of the responsible discipline(s)
- the frequency and duration of all visits as well as those items listed in 42 CFR 484.60(a) that establish the need for such services.
All care provided must be in accordance with the plan of care.