Effective January 13, 2018, the “Plan of Care” (POC) Condition of Participation under 42 CFR 484.60 also became a Condition for Payment under the home health benefit, 42 CFR 409.43. This means that all the elements must be in the POC or Medicare payment will be denied. One of the new POC requirements for payment purposes must now include “information related to any advance directives.”
A POC will not be compliant on the Advance Directives requirement if the only entry references whether or not the patient has a Do Not Resuscitate (DNR) order as there are more types of Advance Directives than just DNRs. It is advisable to get your Medicare Administrative Contractors take on how to handle corrections to protect you from the risk of retroactive claim denials based on insufficient advance directive information on the POC.
SDAHO is hosting a home health member call on February 20th to discuss this new condition for payment and review other regulatory updates.