HomeTown Monthly Medicare Call Kerry Dunning, MHA, MSH, CPAR, RAC-CT Kerry Dunning, MHA, MSH, CPAR, RAC-CT Chief Senior Services Officer September 2015

Physician Certs Update your Forms  Original cert must now include “reason”  Physician must sign/date  Can’t predate the next recert Fill in all the blanks Illegible signatures  Transmittal 604 updates Chapter 3, “Verifying Potential Errors and Taking Corrective Actions,” of manual to add some additional leeway, instructing Medicare contractors to also consider alternate sources of medical record documentation, in addition to logs or attestation statements, to determine who authored an illegible signature.  In addition to explaining signature logs and attestation statements, Section in Chapter 3 discusses other aspects of signatures, such as the general prohibition on stamped signatures. GPS HEALTHCARE CONSULTANTS

New Language for Cert GPS HEALTHCARE CONSULTANTS

Recert Language GPS HEALTHCARE CONSULTANTS

Physician Certs Maintain two copies  Medical record  Business file Include Cert/Recert in Triple Check process  A facility may NOT bill without having a physician signed/dated cert/recert Assign responsibility for getting them filled out and signed GPS HEALTHCARE CONSULTANTS

Physician Cert/Recert Key sources of information include: 1. Chapter 4, “Physician Certification and Recertification of Services,” of the Medicare General Information, Eligibility, and Entitlement Manual (manual ). Section 40 provides details about who can sign certs/recerts, what information certs/recerts must contain, the timing requirements for certs/recerts, the use of delayed certs/recerts, and more. 2. Chapter 8, “Coverage of Extended Care (SNF) Services Under Hospital Insurance,” of the Medicare Benefit Policy Manual (manual ). Section 40.1 has additional information about when physician assistants, nurse practitioners, or clinical nurse specialists can — and cannot — sign certs/recerts, defining what constitutes both direct and indirect employment relationships with SNFs. Also, CMS survey-and-certification memo NH has a handy table, “Authority for Non-physician Practitioners to Perform Visits, Sign Orders and Sign Certifications/Recertifications When Permitted by the State.” 3. Chapter 6, “Intermediary Medical Review Guidelines for Specific Services,” Medicare Program Integrity Manual (manual ). Section 6.3 instructs medical reviewers: “Claim denials should be made for failure to comply with the certification or recertification requirements. … Claim denials may not be made for failure to use a certification form or particular format.” 4. MLN Matters article SE1428. This article provides examples of incorrect certs/recerts found during CERT audits, as well as breaking down requirements into easy-to-read bullet points. GPS HEALTHCARE CONSULTANTS

QUESTIONS for GPS? 7 GPS HEALTHCARE CONSULTANTS

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