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CMS "Clarification" for Physician Orders

In a January 23, 2018 Frequently Asked Questions (FAQ) release from CMS, we discovered some interesting and concerning information. Most of the 10 page document contained information copied and pasted from the Conditions and the most recent interpretive guidelines in Appendix B. However, in this FAQ document CMS is now providing a different interpretation in a very important part of this document.

Orders written by the ‘relevant’ physician re: §484.60:

Question: “When must orders from relevant physician be approved?

CMS Answer: “Orders from the relevant physicians are incorporated into the plan of care and the HHA clinical manager or other staff are responsible for integrating orders from both the responsible physician and any relevant physicians. If the HHA staff have concerns regarding the integration of orders, the staff would work with the relevant physician issuing the order and the responsible physician to resolve those concerns. The revised plan of care may be approved by the responsible physician to resolve at the next recertification cycle provided those orders are still active at the time. Short duration orders that are added to the plan of care that are no longer active at the recertification period only need to be approved by the responsible physician if those orders are for services that will be provided by the HHA. The HHA should have policies for the co-signature of orders for services to be provided until the plan of care is signed at the next re-certification period.

The original language in the CoP’s has been very confusing. Many agencies are making copies of the relevant physician orders and simply sending a copy to the responsible physician. This most recent direction is more confusing and is inconsistent with earlier recommendation by CMS. NAHC and your State organizations are working on getting more information. Stay tuned!!

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