Good morning,

 

Sharing the below NAHC update regarding a recent Palmetto notice to HHAs under RCD that stated effective 5/20/24, a “hand off” signed by the initial certifying provider would be required whenever the overseeing HC provider is going to change.  This generated a lot of questions and concerns from HHAs, and NAHC reached out to CMS regarding this.  Below is a post from a NAHC listserv yesterday:

“NAHC has been receiving questions about an article posted on the PalmettoGBA website regarding a requirement that home health agencies must have a physician-signed statement of a "hand off" occurring when a physician recertifies home health.  The article was intended for participants in the Home Health Review Choice Demonstration (RCD).  However, PalmettoGBA applied the requirement to all home health claims under review as did the other Medicare Administrative Contractors (MACs).  There is not a requirement for a physician-signed "hand off" under any circumstance in home health.  As soon as NAHC became aware of the situation we reached out to CMS (Center for Medicare & Medicaid Services).  Since then, the article has been taken down and, in a meeting, earlier this week where PalmettoGBA and CGS representatives were present, they confirmed that they are not applying the "hand off" requirement as part of RCD or medical review of claims.  We understand that the same is true for NGS, but we have reached out to them for confirmation.

CMS as well as PalmettoGBA has indicated that all MACs will be posting a revised article.  No expected timeline has been given.  Based upon discussion at the meeting earlier this week, we anticipate that any reference to a physician-signed "hand off" will be removed from the article. Home health agencies that have had claims denied due to the lack of a "hand off" should appeal those denials. Likewise, home health agencies participating in the pre-claim review option for RCD that have had non-affirmations for this reason, should submit the Document Control Number (DCN) to PalmettoGBA for correction.

Stay tuned to NAHC Report and NAHC Communities for updates to this situation as they become available.

Katie Wehri
Director of Home Health & Hospice Regulatory Affairs
NAHC”

 

 

Though Minnesota is not currently an RCD state, I appreciate the industry responding quickly and preventing possible issues to all HHAs down the road.

 

Thanks,

Jen