Home Health & Hospice

Late Recertifications Can Result in Scrutiny

Homecare Insider, April 26, 2010

Oh, oh!  It’s the fifth day of the recertification episode and the nurse realizes she did not do the follow-up assessment during the five-day window.  Now what? 

This omission can be expensive.  For Medicare patients, the agency cannot bill for services without a recertification assessment.  A tardy assessment delays submission of the request for anticipated payment (RAP).  Thankfully, the solution is relatively simple — send the nurse to update the assessment as soon as possible after discovering the omission.

But that’s the only simple thing about this dilemma.  Let’s review some of the issues.

  • The agency will receive a warning message because the dates of OASIS data collection are outside the appropriate time frames.  Do not, however, change the dates of the certification period or the start of care to prevent this warning.  Such actions would create other problems, such as an intermediary challenge the continuous nature of care. 
  • Do not submit the RAP for the recertification episode until the assessment data are collected and locked, and the first billable visit has been made. 
  • Determine whether or not the agency can bill for any visits made in the recertification episode before the assessment was done.  Example:  The aide made five visits before the nurse did the assessment.  If the nurse remembered to renew the plan of care for ongoing services, but forgot the assessment, the agency has authorization for the visits.  However, if the nurse forgot to do the assessment, there’s a good chance he or she also forgot about the plan of care.  In that case, the agency has no authorization for the visits made before the plan was renewed and cannot include those visits on the claim. 

If tardy assessments occur with regularity, the agency can face scrutiny.  Beacon Health’s audio conference on May 20, 2010, will present a defense for Medicare audits.  Learn more about this educational session at — http://www.beaconhealth.org/audio_conferences.php.