New home health agencies "face to face" paperwork requirement:
-Recently CMS, in an effort to combat home health abuses and fraud, has offered a change in regulation that requires additional documentation by "physicians". That includes documenting, on a separate form, patients' home bound status, the reasons for home based services, and documenting the date of last physician visit, which has to be within 30 days if recent discharge from rehab or hospital, and within 90 days if patient is already at home.
CMS "suggested" that physicians do the documentation, and so all national home health agencies have now created a new form for the physician to fill out and sign (NPs can't sign it because CMS rules don't mention Physician extenders). This is in addition to what physicians already document in their progress notes and the physician discharge orders, which are already mandated under other rules.
Please note that prior to this regulation, the home health agency had to establish "home bound status" themselves as they accepted a new referral, or on their first home visit. The providers (doctors and physician extenders) wrote orders in patient's charts for the services needed, and the other disciplines i.e. rehab, social services, and nursing did their own documentations of patient status and home needs post discharge from inpatient setting. The other disciplines input was taken into consideration by providers when ordering the post discharge home health services.
With the new regulation, there is a duplication of paperwork, but more importantly, there is a shift of responsibility from home health agencies to doctors in documenting home bound status, which then legitimizes future abuses by home health when they continue to provide services to patients who are no longer home bound, undermining the reason for which this whole new regulation was developed.
There are many patients who leave the rehab facilities "home bound" and cease to be "home bound" in the days and weeks post discharge. Having a signed document by doctors stating that these patients are home bound (until the end of times) absolves home health agencies from making any follow up evaluation of patients' home bound status and in turn absolves CMS from any monitoring of home health agencies on this issue, where prior abuses were considered an issue by CMS.
The duplicative paperwork by the physicians is only serving the purpose of protecting home health agencies from future scrutiny by CMS and does nothing to limit abuse by home health agencies. So why would CMS offer new rules that protects recent system abusers from future CMS citations and add to the physicians' paperwork in the process.
Why is CMS responsible is dead wrong on this issue?
. In this case, CMS maybe violating the 1980s "paperwork reduction act" outright.
Aside from that, CMS is shielding home health agencies from future fraud and abuse claims by allowing them to no longer be accountable for establishing patients' home bound status on their own. It would not be a stretch to assume that CMS based these new home health friendly rules on the advise of home health agencies themselves without any independent scrutiny.
.CMS is also covering its own failure for not monitoring home health agencies adequately in the past, by erroneously concluding that all that was needed is one more piece of paper signed by doctors to make this particular abuse issue disappear.
.CMS does not attach any reimbursement to this added paperwork provision.
.CMS has created a situation where NPs or PAs can order the home health services, but only physicians can sign the associated forms, because in the regulation, the word "physician" was used instead of "provider".
Why are we helpless to fix this CMS error?
CMS is huge, inflexible, and no longer accessible to the average advocate or physician. It's own commissioners quit citing inability to affect change.
Solution, more Transparency, less corporate say at the decision making level at CMS, more independent voices at CMS to see through the boast advise given by corporate healthcare.
Where is the AMA and other professional organizations when all this is going on?
Good question!
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