CMS Addresses Denials of HHA Claims Related to Face-to-Face Documentation Issues

CMS has notified providers that it is aware that some Medicare contractors are denying payment for patients who use home health services following an acute or post-acute stay when the home health agency (HHA) uses a single form (i.e., CMS-485) for the plan of care and the certification with a single signature by the community physician who assumes oversight of the patient’s home healthcare. CMS confirms the situations in which the CMS-485 form satisfies all of the certification and plan of care content requirements and will be accepted by the Medicare contractors. Additionally, CMS has learned that some contractors are denying claims for failure of the acute or post-acute physician to identify the community physician who will assume care for the patient. CMS notes that it has not mandated a specific documentation protocol to hand-off a patient to the community physician. For claims that have been previously denied for these reasons, contractors have been instructed to reopen and determine if face-to-face requirements have been met upon request of the HHA.

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