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Kerry Dunning, MHA, MSH, CPAR, RAC-CTKerry Dunning, MHA, MSH, CPAR, RAC-CTChief Senior Services OfficerChief Senior Services OfficerSeptember 2015 September 2015

Physician CertsPhysician Certs Update your Forms

Original cert must now include “reason” Physician must sign/date Can’t predate the next recert

Fill in all the blanks Illegible signatures

Transmittal 604 updates Chapter 3, “Verifying Potential Errors and Taking Corrective Actions,” of manual 100-08 to add some additional leeway, instructing Medicare contractors to also consider alternate sources of medical record documentation, in addition to logs or attestation statements, to determine who authored an illegible signature.

In addition to explaining signature logs and attestation statements, Section 3.3.2.4 in Chapter 3 discusses other aspects of signatures, such as the general prohibition on stamped signatures.

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New Language for CertNew Language for Cert

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Recert LanguageRecert Language

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Physician CertsPhysician Certs

Maintain two copies Medical record Business file

Include Cert/Recert in Triple Check process A facility may NOT bill without having a physician

signed/dated cert/recert Assign responsibility for getting them filled

out and signed

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Physician Cert/RecertPhysician Cert/Recert Key sources of information include:1. Chapter 4, “Physician Certification and Recertification of Services,” of the Medicare

General Information, Eligibility, and Entitlement Manual (manual 100-01). Section 40 provides details about who can sign certs/recerts, what information certs/recerts must contain, the timing requirements for certs/recerts, the use of delayed certs/recerts, and more.

2. Chapter 8, “Coverage of Extended Care (SNF) Services Under Hospital Insurance,” of the Medicare Benefit Policy Manual (manual 100-02). Section 40.1 has additional information about when physician assistants, nurse practitioners, or clinical nurse specialists can — and cannot — sign certs/recerts, defining what constitutes both direct and indirect employment relationships with SNFs. Also, CMS survey-and-certification memo 13-15-NH has a handy table, “Authority for Non-physician Practitioners to Perform Visits, Sign Orders and Sign Certifications/Recertifications When Permitted by the State.”

3. Chapter 6, “Intermediary Medical Review Guidelines for Specific Services,” Medicare Program Integrity Manual (manual 100-08). Section 6.3 instructs medical reviewers: “Claim denials should be made for failure to comply with the certification or recertification requirements. … Claim denials may not be made for failure to use a certification form or particular format.”

4. MLN Matters article SE1428. This article provides examples of incorrect certs/recerts found during CERT audits, as well as breaking down requirements into easy-to-read bullet points.

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QUESTIONS for GPS? QUESTIONS for GPS? QUESTIONS for GPS? QUESTIONS for GPS?

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Contact GPS HealthcareContact GPS Healthcare

Kerry Dunning

Chief Senior Services Officer

Kerry.Dunning@GPShealthcon.com

904-923-7229

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CONSULTANTS 314-450-5880