Reps. Reed and Tonko Invite Colleagues to Sign Onto a Letter Urging CMS to Suspend Home Health Claim Denials Arising from F2F Physician Narrative Requirement
Deadline for signatures is August 7, 2014; NAHC urges its members to contact their Representatives and ask for their support
July 31, 2014 11:09 AM
Rep. Tom Reed (R-NY) and Rep. Paul Tonko (D-NY) are urging their colleagues to join them in sending a letter to CMS Administrator Marilyn Tavenner urging her to suspend claim denials, including reversing previous denials, arising from the Face-to-Face (F2F) physician narrative requirement pending adoption of the final F2F rule eliminating the narrative requirement.
Recently, CMS released its 2015 proposed Home Health Prospective Payment System (HHPPS) rule, which will go into effect on January 1, 2015. Reps. Reed and Tonko – urged on by the successful advocacy of New York and New Jersey NAHC members - were instrumental in getting 77 other Representatives to join in a previous F2F letter last September.
For more on CMS’ HHPPS rule, please see NAHC Report, July 8, 2014.
In the Proposed Rule, CMS made strides in improving the F2F requirement to improve access to care in home health services by proposing to eliminate the physician narrative requirement.The proposed rule did not, however, account for previous denials and future denials occurring before January 1, 2015 - an important oversight that Reps. Reed and Tonko are urging be corrected.
The letter that Reps. Reed and Tonko are urging their colleagues to support states that:
“We acknowledge that progress was made towards eliminating the required physician narrative as part of the Face-to-Face (F2F) requirement in the 2015 proposed HHPPS rule and support the inclusion of this provision in the final rule. However, concerns remain over the providers and patients whose claims are still being denied due to an insufficient physician narrative while they wait for the rule to be finalized. CMS signaled with the proposed rule that it intends to no longer enforce the physician narrative requirement. Therefore, we urge CMS to suspend audits related to the physician narrative beginning with the date that the 2015 proposed HHPSS rule went on display (July 1, 2014). Similarly, in light of the changes announced in the proposed rule, we urge CMS to establish a process that would allow providers to receive full reimbursement if a claim was previously denied for an "insufficient physician narrative."”
NAHC encourages all of its members to contact their Representative and ask them to sign-on to this latest F2F letter.
Click here for a current list of the health staffers in each House office, including contact details, please click here.
The health staffers should have received a copy of the sign on letter, but if they say they’ve not seen it, offer to forward it to them. A link to the sign-on letter can be found here.
You may suggest that Republican staffers contact Reed’s office and Democratic staffers contact Tonko’s office if they are interested, have questions, or need more information.