AHCC Opposes Medicare Prior Authorization of Home Health Services Demonstration Proposal

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Written comments by AHCC formally submitted in opposition of CMS’ demonstration proposal

AHCC Home of BMSC & Caring Professionals

"...We do not believe a prior authorization process will decrease fraud, but will instead increase the costs of providing services for both providers and Medicare,” says Corinne Kuypers-Denlinger, AHCC Executive Director.

The Association of Home Care Coding & Compliance (AHCC), and its credentialing body, the Board of Medical Specialty Coding & Compliance (BMSC) submitted written comments to CMS’ Office of Strategic Operations and Regulatory Affairs in opposition to the Medicare Prior Authorization of Home Health Services Demonstration proposal.

AHCC presented concerns, speaking on behalf of the home care community, that if prior authorization is implemented, the burdensome administrative demands on home health agencies will adversely affect both the agency and the Medicare beneficiaries they serve. The requirements of Medicare’s Home Health Conditions of Participation (CoPs) stipulate initiation of service as ordered by physician or within 48 hours, whichever comes first. However, the entire process will take at least 48 hours – more likely longer. Under CMS’ proposal, patients will remain in the hospital longer, be discharged to a more intensive facility than needed, or discharged to a home without skilled services; virtually guaranteeing an increase in rehospitalizations.

AHCC positioned that honest providers endeavor to serve those in need and receive proper payment for services rendered, but the challenge remains for physicians to comply with agency requests for needed information. Without proper documentation, claims may be denied and categorized as fraudulent.

CMS continues its attempts to rid the process of fraudulent claims. AHCC reiterates its argument that the face-to-face requirement and the face-to-face probe have not resulted in a decline in fraud. “Although, we stand with CMS in regards to ridding the program of fraud and abuse, we do not believe a prior authorization process will decrease fraud, but will instead increase the costs of providing services for both providers and Medicare,” says Corinne Kuypers-Denlinger, AHCC Executive Director.

AHCC braces for a response from the CMS that will either kill the proposal, make changes, or move forward despite opposition. No matter the outcome, AHCC continues to speak on behalf of home health professionals, ensuring that the home care industry’s voice is heard.

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About AHCC and BMSC
AHCC is the community for professionals dedicated to providing quality care in post-acute care settings and establishing, meeting, and maintaining standards of excellence in their area of expertise.
AHCC’s credentialing arm, the Board of Medical Specialty Coding & Compliance (BMSC), offers professional credentials, including the only nationally accredited home health coding credential that tests coding skills exclusively, the Home Care Coding Specialist—Diagnosis (HCS-D), and the nationally accredited Home Care Clinical Specialist—OASIS (HCS-O), and the Home Care Coding Specialist—Hospice (HCS-H) launched in February 2016.

BMSC has been credentialing home health coders since 2003. More than 63% of agencies require coders to have earned the HCS-D credential as a condition of employment. The credentials are overseen by an independent board of home health and OASIS experts nationally recognized as leading authorities. Each board member has more than 25 years of experience in home health and hospice, and all are in-demand home health and hospice coding educators.

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Corinne Kuypers-Denlinger
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