On Friday, April 21, 2006, CMS published the final rule governing enrollment as a Medicare provider. The new rule is designed to reduce fraudulent or abusive Medicare billing practices. It includes a new standard enrollment requirement and requirements for periodic updates of provider information.
The new regulation is effective on June 20, 2006.
Although I have not yet had time to read through the entire rule, here area few highlights I noticed. (I intend to read through the rule and comments today and have more details posted this afternoon or tomorrow.) I have attached a copy of what was printed in the Fedral Register on Friday to this post.
All providers will be subjected to a five-year “recertification” cycle. This will require a submission of certain information every five years. Just in case you did not have enough paperwork to do already. (A regulator’s response to most issues – require more paperwork.)
CMS reserves the right to require “off cycle” revalidations more frequently than every five years. CMS also reserves the right to increase the frequency of revalidations under certain circumstances.
In other news, I have to mention next week is the Indiana Association for Home and Hospice Care’s Annual meeting. I mention it, not only because I will be presenting at a few sessions there, but because it is an excellent opportunity to meet your colleagues and learn something new about your industry. Of course, every year I present the annual health law update, but this year our firm is also doing a bonus seminar on employment law. I will be addressing non-compete agreements in home health.
For those of you reading in Indiana, if you are there, I expect I will see you next week. (If you are going or thinking about going, and have not sent in your reservation, contact IAHHC.)
Finally, after three of four months of blogging, I have confirmed that this blog is actually being read by somebody besides me. For those of you who do read it, thanks. Also, if you ever have any thoughts or suggestions, feel free to let me know. I am still tinkering with this blog and reader’s thoughts would be helpful. Again, thanks for reading.
Attachments:
71_fr_20754.pdf
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A few weeks ago I taped a video seminar on the new HHABN form and instructions. One of the questions that came up during that presentation was whether Option Box 1 or Option Box 2 should be used when reducing or terminative services due to a lack of physician’s orders.
Because Doctor’s orders are needed as a matter of professional practice, there was an argument that Option Box 2 should be used. (The argument was basically, without a doctor’s order, a home health agency can’t provide the care regardless of whether the desired care would be covered or not and, therefore, this was a decision related to professional practice limitations and unrelated to Medicare coverage.)
We discussed this issue at length before taping and, in my opinion, explained the rationale for each option. CMS has since indicated in a Q&A that it feels Option Box 1 is appropriate whenever you are reducing or terminating services due to a lack of doctor’s orders.
CMS’s rationale is that doctor’s orders are required for coverage under Medicare. Therefore, if you no longer have Doctor’s orders, your decision to terminate is related to Medicare coverage. Based upon this “clarification” from CMS, it is probably a good idea to use Option Box 1 in this situation.
During this conference call, CMS cautioned providers that some changes may be made to the HHABN form. Although any potential changes were described as minor, CMS noted that providers printing the HHABNs in bulk may end up needing to reprint the HHABNs with the revisions.
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