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

2. 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 100-08 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 3.3.2.4 in Chapter 3 discusses other aspects of signatures, such as the general prohibition on stamped signatures. GPS HEALTHCARE CONSULTANTS 314-450-5880 2

3. New Language for Cert GPS HEALTHCARE CONSULTANTS 314-450-5880 3

4. Recert Language GPS HEALTHCARE CONSULTANTS 314-450-5880 4

5. 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 314-450-5880 5

6. 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 100-01). 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 100-02). 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 13-15-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 100-08). 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 314-450-5880 6

7. QUESTIONS for GPS? 7 GPS HEALTHCARE CONSULTANTS 314-450-5880

8. Contact GPS Healthcare Kerry Dunning Chief Senior Services Officer Kerry.Dunning@GPShealthcon.com 904-923-7229 8 GPS HEALTHCARE CONSULTANTS 314-450-5880