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Hospice Recertification Requirements Under CMS 2011 Home Health Prospective Payment System

In its November 3, 2010 release of the final 2011 Home Health Prospective Payment System (“2011 HHPPS”), the Centers for Medicare and Medicaid Services (“CMS”) updated its hospice recertification requirement. Beginning January 1, 2011, the Affordable Care Act requires that physicians and non-physician practitioners attest to a beneficiary’s recertification for hospice eligibility through a documented face-to-face encounter. This documentation is required to be signed and dated and is separate and distinct from recertification.

Many hospices and providers were concerned about the burden this new requirement would place on hospices. CMS responded, in part, by providing that “[t]he burden for completing the attestation form is estimated at 30 seconds for each recertification at 180 days or beyond.”

Whereas the requirement for 2010 merely required that “the recertifying physician include a brief narrative explanation of the clinical findings…support[ing] continued hospice eligibility,” the 2011 requirements expand this “to require this narrative to describe why the clinical findings of the face-to-face encounter, occurring at the 180-day recertification and all subsequent recertifications, continue to support hospice eligibility.”

This final rule will be posted in the Federal Register on November 17.

For more information, please contact Abby Pendleton, Esq. or Jessica L. Gustafson, Esq. at (248) 996-8510 or (212) 734-0128 or visit the Hospice specialty page on the HLP website.

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