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HH Agencies Must Include Hand-Off Documentation if Certifying Provider Changes

Home health agencies that participate in a Review Choice Demonstration have a new rule starting May 20 to avoid claim denials.
Beginning May 20, 2024, home health agencies must submit with patient records documentation of a hand-off from any original certifying provider to a subsequent provider.
Palmetto posted this new rule May 14, giving agencies less than one week to prepare for the change.
Here's some of what Palmetto posted:

If one physician or nonphysician practitioner (NPP) performs the original certification, and a different physician or NPP is recertifying, Medicare needs to see the hand-off between practitioners. 

For example, if "Dr. A" signed the initial certification and "Dr. B" signed the recertification, there should be documentation signed by "Dr. A" that the patient was handed off to "Dr. B." This is acceptable.

If multiple physician/NPP changes have occurred, Medicare needs documentation for each hand-off. In this example, let’s assume "Dr. A" signed the initial certification, and "Dr. D" signed the fourth recertification. There is documentation of a hand-off to from "Dr. A" to "Dr. B" present, but it is signed by "Dr. C." This is unacceptable as there must be a hand-off of care between each physician or NPP in the chain.

Rather than specifying how agencies are to provide this information, Palmetto wrote "There is no designated format or form that must be used to show the hand-off. Documentation can include, but is not limited to, progress notes, orders to change primary physician or NPP, or anything that shows the change(s) in certifying provider."
References that Palmetto cited to back up its new requirement are:
Best to quickly get a process in place for this.
Be well.

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