NAHC is further holding on filing the lawsuit to give CMS the chance to assess the concerns and the changes sought by the trade association.

In March, the National Association for Home Care & Hospice (NAHC) informed that it had decided to file a lawsuit over onerous face-to-face physician encounter requirements. But the trade group postponed the filing of the suit so it could meet with the CMS on the issue. A couple of months back, on May 8, 2014, the group’s representatives met with CMS. The main goal of the trade group is to secure elimination of the physician narrative portion of the F2F requirement.

HHAs have long challenged that while the F2F encounter requirement is contained in the ACA law, the narrative portion of the requirement is not.

Lawsuit will wait

Based on the discussions at the meeting with CMS, the trade association is further holding on filing the lawsuit to give CMS the chance to assess the concerns and the changes sought by NAHC.

The trade group has also expressed that if they see that they are not making enough and fast progress with CMS, the lawsuit is fully prepared for immediate filing in federal court.

The means for CMS to bring F2F regulatory change would be the 2015 home health prospective payment system rule. The agency will propose in late June or early July.

The trade association and other industry reps have criticized the F2F audits recently launched by Supplemental Medical Review/Specialty Contractor Strategic-HealthSolutions. An OIG report showed that those SMRC audits will hit every single home health agency across the country. However, they are eyeing an all-embracing suspension of enforcement of the physician narratives by all of the Medicare contractors, meaning Medicare would continue to assess all other elements of Medicare coverage and the F2F requirements.

However that does not mean you can stop collecting physician narratives. Firstly, the Centers for Medicare and Medicaid doesn’t even consent to suspend the narrative part of F2F review. CMS has proven intractable previously as far as the F2F issue is concerned.

Between now and the issuance of a final rule, several discussions and meetings have been prepared. At each meeting, NAHC will assess progress to determine if litigation is necessary. For more on F2F requirements and the latest home care news, stay tuned to http://www.supercoder.com/coding-newsletters/my-homecare-week-alert

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Even though some provider types now have the Form CMS 339 Questionnaire included in their cost reporting form, HHAs and hospice providers are still required to file a separate Form CMS 339.

These days home care providers have a new issue to deal with – cost report confusion. So if you do not meet cost and report related requirements, don’t be surprised if your payments take a hit.

Background: Recently, Palmetto GBA informed the provider community that quarterly Credit Balance Reports were due April 30, 2014. Suspension Warning letters were mailed that read suspension of all claims reimbursements at 100% would commence in 15 days from the date of issuance of the letter if the credit balance report is not received on time. The suspension started with June 3 Remittance Advices and will continue until the credit balance report is received.

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Once the RACs start looking at your claim, they’ll check out everything including F2F documentation, technical items, and more.

Early in 2014, three of the four Medicare Recovery Audit Contractors (RACs) – CGI, Connolly and Healthdata Insights – announced two issues for home health agencies:

a)      Home health medical necessity and conditions to qualify for services

b)      Skilled Nurse Length of Stay.

Broad audit review could be challenging for HHAs

The issue of medical necessity taken up by the three MACs is very broad and could be a problem, according to experts. As many wonder how the RACs will go about determining how to select claims for ‘medical necessity’ review, you need to watch your steps because once the RACs start looking at your claim, they will review everything including face-to-face documentation, technical items, among others.

While checking medical necessity, the medical record will be reviewed to check that the home health services were both reasonable and medically necessary and that the patient met the conditions to qualify for home health services.

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Don’t stick with this No. 1 bad habit known to cause injuries.

Prevention is the best remedy for needlestick and other sharps injuries, which can be largely avoided if you follow these key strategies.

1. Know the ropes for safely disposing of sharps. The Occupational Safety and Health

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