Home health agencies (HHAs) experiencing payment denials for inadequate documentation of the face-to-face encounter have gained a measure of relief from CMS’s recent clarification of these requirements. Some Medicare contractors have been using a hypertechnical reading of the documentation and signature requirements to deny payments in situations where the home health episode follows an acute or post-acute stay. In these instances, the community physician who assumes care of the patient after discharge and who is responsible for overseeing and updating the plan of care often signs a single form (the CMS 485 form) that contains both the plan of care and the certification of the need for home health services. The acute or post-acute physician certifies eligibility and the need for home health services and is signing an addendum containing the documentation of the face-to-face encounter. The problem has been that the acute/post-acute physician is the one doing the certification of need, but the 485 has only one signature line so it appears that the community physician is signing the certification.
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