Regulatory Review

Expedited Review Process:

Masspro completed a series of workshops to discuss the “expedited review process,” used by home health agencies to notify Medicare beneficiaries that their Medicare services are ending. There are two separate forms and slightly different rules depending on Medicare “fee-for-service” (Notice of Medicare provider Non-Coverage) or Medicare Advantage (Notice of Medicare non-Coverage).  These forms are to be used when all Medicare services are ending for medical reasons.  If care is ending for a technical reason such as homebound, then the beneficiary is given a HHABN.  This is a recent clarification from Quest to Masspro our local QIO.

Quest is the part of the Quality Net system that QIO’s use to communicate with CMS.  QIO’s can ask Quest questions that require clarification by CMS and then publish the answers.

Is it appropriate for the HHA to issue a Notice of Medicare Provider Non-Coverage in these types of cases, and for the QIO to review?


It is not appropriate for HHAs to issue Notices of non-coverage for home-bound status; only when it is believed that the beneficiary no longer requires a skilled level of care


CMS put out a transmittal a few weeks ago to define several dates that relate to the Face-to-face Requirement.

The effective date is January 1, 2011

The implementation date that CMS contractors must have their systems ready is March 10, 2011

The enforcement date is April 1, 2011. After this date, agencies will not be reimbursed if the F2F documentation is not present in the medical record.

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