While there have been many changes to current requirements granted as administrative relief during the current Public Health Emergency (PHE), perhaps the biggest has been allowing non-physician practitioners (NPPs) to certify patients for home health as well as sign orders. CMS Flexibilities
While allowing Nurse Practitioners (NPs), certified Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) to certify beneficiaries for eligibility and oversee the plan of care was a big change, it was understood to be a temporary measure. However, Medicare Administrative Contractor (MAC) Jurisdiction M Palmetto GBA has now added a key element to this change. From the Palmetto GBA website:
“Section 3708 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. No. 116-136) amended sections 1814(a) and 1835(a) of the Social Security Act to allow Nurse Practitioners (NPs), certified Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) to certify beneficiaries for eligibility under the Medicare home health benefit and oversee their plan of care. This is a permanent change that will continue after the Public Health Emergency.”
The most important part of that is that Palmetto GBA has now indicated that this change will be permanent. This will allow NPPs, when allowed by state requirements, to continue these functions after the end of the PHE. This should give home health agencies much more flexibility in obtaining certification and maintaining compliance with home health certification and plan of care requirements.
With the caveat that the relevant parts of the Conditions of Participation, Medicare Benefit Policy Manual, and Title 42 Code of Federal Regulations will need substantial revisions to account for this change, so far this may be the biggest change in application of home health service to come from the PHE.
Joe Osentoski, BAS, RN-BC
ADR and Appeals Specialist
Gateway Home Health Coding & Consulting LLC