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Feds Must Delay Flawed Home Health Program; Your Help Needed

ISMS has received significant feedback from physicians about the Centers for Medicare and Medicaid Services' (CMS) new home health Pre-Claim Review Demonstration (PCRD) program that launched in Illinois on Aug. 3, 2016.

Physicians expressed concern that this policy change has created additional administrative burdens and may ultimately jeopardize access to home health services for Medicare patients.

Here's an overview:

  • Home Health Agencies (HHAs) in Illinois must now submit documentation for services provided to Medicare patients before they submit the actual claim for services. The "pre-claim review" means that agencies are required to collect and submit all documentation much earlier in the process.
  • While the focus of Pre-Claim Review Demonstration is on reimbursement to the agencies, the burden of providing complete and accurate documentation falls on physicians who certify patients for home health services. According to CMS, the documentation requirements have not changed, but HHAs must now submit the documentation for review for every patient referred for home health services.

Illinois was the first of five states that CMS planned for the demonstration, which is intended to close fraud and abuse loopholes associated with home health claims. Since it became obvious that PCRD was not yet ready for "prime time," implementation for the four other states has been put on hold.

Illinois' congressional delegation is aware of this flawed program and has asked CMS to stop PCRD in Illinois. CMS has yet to act on this request.

Congress recently introduced legislation (H.R. 6226) to impose a one-year moratorium on PCRD to allow further study on the implications of the review program.

Call to Action: Please contact your U.S. Representative to urge support for H.R. 6226, also known as the Pre-Claims Undermine Seniors' Health (PUSH) Act.

Read ISMS' letter to Congress
Read ISMS' letter to CMS
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