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CMS Issues Change Request 9898 to the dNPWT

Posted on Wednesday, March 1, 2017 4:35 PM

The Centers for Medicare & Medicaid Services (CMS) issued change request 9898 to manualize their policy on the disposable Negative Pressure Wound Therapy (dNPWT), as well as the revisions to the outlier policy that was released in the 2017 home health prospective payment rate update final rule.

The transmittal also includes the following clarifications regarding the existing policies:
• A clarification was added to section 30.1.1 to provide additional guidance on whether a patient meets the definition of “confined to the home” or “homebound”
• In section 30.5.1, example language has been provided to satisfy the physician certification requirements
• In section 30.5.1.2, clarifications to the supporting documentation requirements that were implemented January 1, 2015 have been added

The manual describes the following:
• CMS’ new policy for coverage of dNWPT
• CMS’ new outlier policy which calculates the imputed cost for each episode
• Stronger guidance is provided to home health agencies about CMS’ expectation for the certification statement, including documentation for beneficiary eligibility

Under section 30.5.1, CMS provides the following example for the certification statement:
“I certify that this patient is confined to his/her home and needs intermittent skilled nursing care, physical therapy and/or speech therapy or continues to need occupational therapy. The patient is under my care, and I have authorized services on this plan of care and will periodically review the plan. The patient had a face-to-face encounter with an allowed provider type on 11/01/2016 and the encounter was related to the primary reason for home health care.”

Under section 30 .5.1.2 in the manual, CMS explains their requirement that the physician’s record supports eligibility:
“Information from the HHA, such as the plan of care required per 42 CFR §409.43 and the initial and/or comprehensive assessment of the patient required per 42 CFR §484.55, can be incorporated into the certifying physician’s medical record for the patient and used to support the patient’s homebound status and need for skilled care. However, this information must be corroborated by other medical record entries in the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient. This means that the appropriately incorporated HHA information, along with the certifying physician’s and/or the acute/post-acute care facility’s medical record, creates a clinically consistent picture that the patient is eligible for Medicare home health services”

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