The Medicare Conditions for Payment of Home Health services can be found at CFR 424.22. It is very important to understand fully the requirements for home health claims to be paid. Recently, our consultants have come across two separate occasions where agencies were releasing bills to Medicare Replacement Payers prior to having all physician orders signed and dated. In both situations, management had concluded that these conditions of payment only applied to Medicare Fee-For Service beneficiary claims. While there are certain waivers of Medicare requirements afforded Medicare Advantage payers, to our knowledge there is no specific waiver on the requirement that orders be signed and dated as a Condition of Payment. Specifically, CFR 424.22 (a)(2) states:
Timing and signature. The certification of need for home health services must be obtained at the time the plan of care is established or as soon thereafter as possible and must be signed and dated by the physician who establishes the plan.
In addition, CFR 424.22 (a)(2)(b) covers the same requirement as related to Recertification:
– (1) Timing and signature of recertification. Recertification is required at least every 60 days when there is a need for continuous home health care after an initial 60-day episode. Recertification should occur at the time the plan of care is reviewed, and must be signed and dated by the physician who reviews the plan of care.
While we understand that most MA plans pay per visit amounts and billing requirements are different than Medicare PPS claims, however the requirement that services be appropriately certified and that orders must be signed and dated prior to billing are covered in this CFR.