*If you registered yesterday 12/11 to please resubmit a registration*

Last week in the Pre-Claim Review webinar conducted by Palmetto GBA, an announcement was made that Palmetto nurses performing Pre-Claim Review will no longer “affirm” claims where the face-to-face encounter is performed by Nurse Practitioners in the physician’s office or in the home AND the certifying physician is different on the plan of care. Only the physician could perform the face-to-face in this situation.

It remains acceptable for NPPs to perform face-to-face encounters in acute and post-acute care facilities IF the patient is a direct admission to home health from the facility.

The issue places immediate non-covered risk to all face-to-face encounters performed by NPs in Pre-Claim, Targeted Probe and Educate, or ADR reviews conducted by Palmetto.  

The different interpretation by Palmetto has not been put in writing formally by CMS or Palmetto and will most likely NOT be occurring. There is also no intent to “grandfather in” the prior interpretation for any current reviews. In fact, during the webinar, Palmetto posted portions of the federal Code of Federal Regulations (§ 484.2) and the Medicate Benefit Policy Manual (IOM, Chapter 7, Section 30.5.1) that are the support the new standard of review. It appears that the 2020 manual revision is at the crux of the interpretation problem.

The home health industry will be greatly affected by this interpretation change. Physician practices will also have to change internal procedures if the practice has NPs who perform F2F encounters. They will likely receive no written information from CMS or Palmetto as well. It will be the home health agency that has to alert the physician.

Legal action may be required to protect the home health industry and its patients who are at great risk from non-covered health care at the most vulnerable time of the year. Attorneys in several Texas cities have been alerted and are considering possible legal strategies for relief to the providers. MJS can refer you to the attorneys who are working on possible action.

MJS IS READY TO HELP!

Webinar This Week!

Scroll below to register for a FREE 30-minute webinar hosted by MJS. The webinar will provide information on how Palmetto will be interpreting face-to-face documentation for Pre-Claim, TP&E, and ADR activities! The webinar will address immediate action you can take to correct any issues you may have and obtain payment.  

Consulting Services

MJS is offering a provider consulting package specific to the issues presented by Palmetto’s changes. The package is designed to provide specific strategies for the agency that has had NPs performing face-to-face encounters in physician practices. MJS will work with the agency to develop both pre-bill and post-bill procedures to help meet the challenges of the new interpretation of medical review. Click the link on the right to see specifics of the consultation services.