Family physicians who refer their Medicare patients for home health services, order home health services and/or certify patients' eligibility for the Medicare home health benefit could see their administrative load lighten just a little next year.
That's because on July 1, CMS proposed changes to the Medicare home health prospective payment system for 2015 that included three modifications to the home health face-to-face requirement that has been in effect since Jan. 1, 2011.
The AAFP intends to closely review the proposed rule, which was published in the July 7 Federal Register(www.gpo.gov), and likely will respond to CMS with comments by the Sept. 2 deadline.
Of primary significance to family physicians, CMS has proposed eliminating the narrative requirement of the certification process in which the physician describes why the patient is homebound and explains the skilled nursing services, physical therapy or speech language pathology services that the patient will require at home.
However, physicians still would be required to certify that a face-to-face encounter with the patient occurred and document the encounter date.
In addition, according to a CMS fact sheet(www.cms.gov), the agency proposes to
- consider only medical records provided by the patient's certifying physician or discharging facility when determining a patient's initial eligibility for home health services, and
- classify as "non-covered" a physician's claim for work involved in certifying or recertifying a patient's eligibility for home health services if the home health agency claim was considered a non-covered service because the patient was deemed ineligible for the home health benefit.
Last among other items in the proposed rule was CMS' request for comments on its proposed home health value-based purchasing model that would include a 5 percent to 8 percent payment adjustment related to performance standards based on quality and efficiency metrics that would be applied to payments made to participants after each planned performance period.
If finalized, that provision would be implemented in 2016 and would include five to eight yet-to-be-named states.
CMS estimated that about 3.5 million Medicare patients received home health services from nearly 12,000 home health agencies in 2013 at a cost of nearly $18 billion. The changes suggested in the proposed rule would reduce Medicare payments to home health agencies by 0.3 percent, or about $58 million, in 2015.
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CMS: Home Health Agency Center(www.cms.gov)