Physician Face-to-Face Call Details Role of Inpatient Physician

In a previous newsfeed post, it was stated that, according to 42 CFR 424.22, as a condition for payment, the content of a home health certification includes a signed statement that:

* The patient needs intermittent skilled nursing or therapy
* Home health services are required because the patient is confined to home
* A plan for furnishing the services has been established
* Services were furnished while the patient was under the care of a physician

The first two bullets under certification requirements were not at issue. However, CMS has responded to questions on how they intend for inpatient facility physicians who end their responsibility to patients will be able to meet requirements for the plan of care and attestation about services administered in the latter two bullet points.

According to NAHC, CMS responded with the following statement:

424.22 (a)(1)(iii) states “A plan for furnishing the services has been established and is periodically reviewed by a physician.”

“As we discussed yesterday, currently, many hospital docs sign the cert and the plan of care for their patients, prior to acute discharge. In this case, long standing practice has allowed the hospital physician’s referral to home care orders to satisfy the establishment of a care plan, and the combination of the hospital doc’s attending role during the remaining acute stay, coupled with the discharge plan which transfers the patient’s care to the patient’s community PCP satisfies the ‘under the care of” requirement.

We believe that in the (hopefully rare) scenario where a hospital doc would sign the cert but wouldn’t (for whatever reason) sign the plan of care, as long as the hospital doc has ordered HH services, we would consider the POC to be initiated. As above, if the hospital doc describes in the discharge plan that the patient will be under the care of a PCP physician at discharge, we would consider the patient to be under the care of a physician at the time of the certification signing. We will allow the doc described in the discharge plan to sign the cert in such a case.

I note that “services were furnished while the patient was under the care of a physician” is a long-standing certification requirement. Long standing practice should ease your concerns here. We’ve never enforced a policy which precluded the certifying physician from transferring care of the patient to another physician. And, we’ve never precluded a hospital physician who was attending to the patient during the acute stay from certifying HH or establishing the care plan. Longstanding practice has allowed the hospital docs referral orders and acute discharge plan which described the patient’s transfer to the PCP physician for continuing care to satisfy the “under the care of’ cert reqmt. We have then looked to the HHA to ensure that the patient remains under the care of a physician during the episode.”

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