Kenyon HomeCare ConsultingThe Year Of The CERT: What CMS Learned And How You Need To Cover Yourself To Get Paid! - Kenyon HomeCare Consulting (206) 721-5091

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The Year Of The CERT: What CMS Learned And How You Need To Cover Yourself To Get Paid!

regulatory complianceMany of you will read this and know exactly what CMS learned. The home health industry has been dealing with lots of changes in the last several years.  However, recent audits have alerted CMS to some issues with plan of care compliance. 

Changes In The Conditions Of Participation: 

If agencies focused on only the big changes to the COP’s, then others probably got missed.  It makes sense that while you try to comply with emergency preparedness, clinical management, and proper governance that something can be missed elsewhere. This is the issue for agencies now. The plan of care condition of participation is now a condition for payment. In order to be compliant for payment purposes, advanced directives info must be present. 

CERT Testing: 

Bill Dombi, President of the National Association of Homecare and Hospice communicated January 9th that Medicare home health agencies need to determine compliance with COP 42 CFR 484.60. This includes proper advanced directive documentation. If proper advanced directive information does not flow to your plan of care properly, then your agency is at risk of retroactive claim denials. This means more than just a DNR notation on a plan of care. Through Comprehensive Error Rate Testing (CERT), CMS evaluates proper coding, coverage and billing rules. This is done with random sampling yearly. The most recent data available is a 9.51% error rate totaling over 36 billion dollars in recoupment for Medicare home health payments from 2017. 

Avoiding Recoupment: 

Does your EMR have the proper information included for staff to input all the needed information? If not, then you need to make changes in operations to make sure a check and balance of the POC or 485 has the information present. Does Oasis contain detailed information on advanced directives? If your agency determines there is information not included on the plan of care, then initiate protocol for an addendum from the MD that includes the information you need for proper payment. You can submit corrected claims accordingly after speaking directly with the MAC about the process. Ultimately, it makes sense to make the changes now prior to massive audits that put your agency on administrative overload. 

Let Us Help You: 

Regulatory compliance can get tough. It can feel like you just keep your head above water in daily operations. At Kenyon Homecare Consulting, senior consultants help with operational flow or education regarding regulations and compliance. Call us today at 206-721-5091 or contact us online. 

Category: Regulatory Compliance

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