Home Health & Hospice

Know the Rules to Refute Misconceptions

Homecare Insider, May 24, 2010

An agency reported to Beacon Health that it received a survey citation because there was no signature or date in Locator 23, nurse’s signature and date of verbal SOC, where applicable, on recertification plans of care for private-pay patients.  The nurses compile these plans of care 10 days before the recertification date.  The physicians working with this agency sign the plans of care before the recertification period begins.  When the agency administrator asked the surveyor about the basis for this citation (why there must be a signature and date in Locator 23 in every case), the surveyor could not produce any written information.  Her response:  It’s implied that the date in Locator 23 is the date the orders were received – written or otherwise.

With no official instructions about how to complete the plan of care, there is nothing implied about the date and signature in Locator 23.  The instructions for completion of this locator, which appeared in the CMS Publication 100-8 (Medicare Program Integrity Manual), said that a clinician must complete this locator when verbal orders are involved at start or recertification of care.  If the agency obtains complete, signed orders prior to the start or recertification date, NA (not applicable) is the appropriate response.  That’s because no verbal orders are involved.  If an agency follows those instructions, then NA can be an appropriate response. 

Study the rules and interpretations regarding completion of the plan of care, including dates and signatures.  Verify that your policies and procedures support compliance.  And know how to prove your case when challenged.

The Beacon Guide to Medicare Service Delivery discusses the recertification process and completion of the plan of care.  Order this manual at — http://www.beaconhealth.org/cgi-bin/ccp51/cp-app.cgi?pg=prod&ref=BGMSD10.