CMS’ Supplemental Medical Review Contractor (SMRC) has launched a new review of home health providers. This additional documentation request will focus on home health services provided for at least 361 days with a recertification date in 2024.
 
“Under the PDGM, reductions in therapy utilization and reimbursement‑driven adjustments to care combinations may introduce potential vulnerabilities, particularly for home health services provided for 361 days or longer, as indicated by internal CMS data,” according to Noridian’s project notice.
 
Last spring, Noridian announced it had completed a review of home health recertifications from 2022, with an 86% error rate for reviewed claims.
 
In this new review, agencies will be expected to provide a long list of documentation, including:
  1. Documentation to support the initial start of care certification period:
    1. Medical Record Documentation of the face-to-face (FTF) encounter and signed attestation for start of care
    2. Initial Start of Care Certification
    3. Signed and dated Initial Plan of Care for start of care including short- and long-term goals
  2. Documentation to support the recertification dates of service under review:
    1. Recertification for date of service and justification for any delayed recertifications
    2. Signed and dated recertification Plan of Care for date of service; including short- and long-term goals with any updates to the plan of care
    3. Recertification FTF encounter and signed attestation for date of service to include homebound/not homebound status
    4. OASIS documentation (recertification date of service, follow-ups, and significant changes)
    5. PT/OT/SLP – Evaluation, plan of care, progress reports, treatment encounter notes, therapy minute logs, and discharge summary to support the recertification date of service
    6. Beneficiary’s need for the level and frequency of home health services provided, including any changes during the period under review
    7. Home health skilled nursing, home health aide, or rehabilitation therapy notes including evaluation and re-evaluation, progress notes, and actual therapy minute grids to support the recertification date of service
  3. Any other supporting/pertinent documentation needed to support home health services
  4. Medical record documentation to support national and local requirements
  5. Providers and/or suppliers are encouraged to review the documentation prior to submission, to ensure that signature information is available. Please include a signature log or signature attestation for any missing or illegible signature within the medical record
  6. If an electronic health record is utilized, include your facility’s process of how the electronic signature is created. Include an example of how the electronic signature displays once signed by the physician
  7. Advance Beneficiary Notice of Non-Coverage (ABN)/Notice of Medicare Non-Coverage (NOMNC)
  8. If medical record documentation is submitted via esMD: Beneficiary identification, date of service, and provider of the service should be clearly identified on each page of the submitted documentation
  9. Please Note: The supplier or provider is responsible for obtaining all documentation from the ordering/referring provider to ensure medical necessity criteria have been met