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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