Update from NAHC regarding Home Health Physician “Hand Off” Directive Confusion

The following was posted by NAHC on June 6, 2024

NAHC has been receiving questions about an article posted on the PalmettoGBA website, intended for participants in the Home Health Review Choice Demonstration (RCD), regarding a requirement that home health agencies must have a physician-signed statement of a “hand off” occurring when a physician recertifies home health. However, PalmettoGBA applied the requirement to all home health claims under review as did the other Medicare Administrative Contractors (MACs). 

There is not a requirement for a physician-signed “hand off” under any circumstance in home health.  As soon as NAHC became aware of the situation we reached out to CMS (Center for Medicare & Medicaid Services).  Since then, the article has been taken down and, in a meeting, earlier this week where PalmettoGBA and CGS representatives were present, they confirmed that they are not applying the “hand off” requirement as part of RCD or medical review of claims. We understand that the same is true for NGS, but we have reached out to them for confirmation.

CMS as well as PalmettoGBA has indicated that all MACs will be posting a revised article.  No expected timeline has been given.  Based upon discussion at the meeting earlier this week, we anticipate that any reference to a physician-signed “hand off” will be removed from the article. Home health agencies that have had claims denied due to the lack of a “hand off” should appeal those denials. Likewise, home health agencies participating in the pre-claim review option for RCD that have had non-affirmations for this reason, should submit the Document Control Number (DCN) to PalmettoGBA for correction.