CMS is clarifying guidance in the Medicare Benefit Policy Manual related to 2021 RAP requirements and the rules around a substitute signature on the plan of care or recertification.
 
The manual updates were released Friday, May 7, with an effective date of Jan. 1, 2021, and an implementation date set for Aug. 9, according to the CMS documentation.
 
The new language in the manual clarifies who can sign the plan of care (POC) or recertification if the certifying physician or allowed practitioner is unavailable. The existing language limits that allowable substitute to another physician or allowed practitioner in the same group practice.
 
The updated language would allow any physician or allowed practitioner to sign the POC or recert, as long as they are authorized to care for the patient in the absence of the certifying physician or allowed practitioner.
 
That removes the reference to the same group practice, but the new manual language requires that the signer is authorized by the original physician or allowed practitioner, notes Melinda Gaboury, CEO of Healthcare Provider Solutions in Nashville, Tenn.
 
The manual update states the agency “is responsible for ensuring that the physician or allowed non-physician practitioner who signs the plan of care and recertification statement was authorized by the physician or allowed non-physician practitioner who established the plan of care and completed the certification for his/her patient in his/her absence.”
 
The second change updates the language around RAP submission requirements, noting the two requirements that must be met before submitting the RAP in 2021:
  • The appropriate physician’s written or verbal order that sets out the services required for the initial visit has been received and documented, as required in regulation at 42 CFR 484.60(b) and 42 CFR 409.43(d);
  • The initial visit within the 60-day certification period must have been made and the individual admitted to home health care.