We have seen this and share your concerns. We understand from Palmetto that this is something all the MACs discussed and agree with, but we have not seen any communication about it from NGS or CGS. A "hand off" as described here by Palmetto is not required for payment nor as a condition of participation. We reached out to CMS about this earlier this week and are continuing conversation with them. We will post updates here.
As a reminder, the Medicare Benefits Policy Manual, Chapter 7, Section 30.5.3 states:
A physician or other allowed non-physician practitioner, other than the certifying physician or certifying allowed practitioner who established the home health plan of care, may sign the plan of care or the recertification statement in the absence of the certifying physician or certifying allowed practitioner. This is only permitted when such physician or allowed non-physician practitioner has been authorized to care for the certifying physician's or allowed practitioner's patients in his/her absence. The HHA is responsible for ensuring that the physician or allowed nonphysician practitioner who signs the plan of care and recertification statement was authorized by the physician or allowed practitioner who established the plan of care and completed the certification for his/her patient in his/her absence.
This is not a "hand-off" and nothing is required to be signed by the physician. Generally, when the physician certifying and signing the plan of care changes, the home health agency notates this in the medical record, the reasons for it and documentation of the communication with the physician. There are times when communication with the physician is not possible, e.g. medical leave, unplanned absence of the physician, etc.
We are working on this and will update this thread when we have new information.
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Katie Wehri
Director of Home Health & Hospice Regulatory Affairs
NAHC
Washington, DC
202-240-9254 #3360
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Original Message:
Sent: 05-15-2024 11:50
From: Kandy Milette
Subject: 5/14/24 - Palmetto - different physician or NPP is recertifying, Medicare needs to see the hand-off between practitioners
Has everyone seen this? Is this just for Palmetto?
I don't see this requirement in the COPs or Federal Register.
Home Health Review Choice Demonstration Certifying Provider Change
Beginning May 20, 2024, home health agencies must submit a hand-off from any original certifying provider to a subsequent provider.
If one physician or nonphysician practitioner (NPP) performs the original certification, and a different physician or NPP is recertifying, Medicare needs to see the hand-off between practitioners.
For example, if "Dr. A" signed the initial certification and "Dr. B" signed the recertification, there should be documentation signed by "Dr. A" that the patient was handed off to "Dr. B." This is acceptable.
If multiple physician/NPP changes have occurred, Medicare needs documentation for each hand-off. In this example, let's assume "Dr. A" signed the initial certification, and "Dr. D" signed the fourth recertification. There is documentation of a hand-off to from "Dr. A" to "Dr. B" present, but it is signed by "Dr. C." This is unacceptable as there must be a hand-off of care between each physician or NPP in the chain.
There is no designated format or form that must be used to show the hand-off. Documentation can include, but is not limited to, progress notes, orders to change primary physician or NPP, or anything that shows the change(s) in certifying provider.
https://www.palmettogba.com/palmetto/jmhhh.nsf/DIDC/4184J8QCJK~Home%20Health%20Review%20Choice%20Demonstration%20(RCD)#:~:text=Home%20Health%20Review%20Choice%20Demonstration%20Certifying%20Provider%20Change,-Published%2005%2F14&text=Beginning%20May%2020%2C%202024%2C%20home,provider%20to%20a%20subsequent%20provider
Resources
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Kandy Milette
A Path of Care Home Health
Norman OK
+1 (405) 928-2727
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