Allegheny Messages

HHC 3000 Main Office software version 6336 dated 07/03/18 will update the Physician Certification language on the Home Health Plan of care print form. Allegheny Software Publishers has been notified by some agencies that Medicare Medical Record Targeted Auditors are refusing payment due to a lack of wording on the Home Health Plan of Care indicating the Physician does not have a direct or indirect financial relationship/ownership, investment or compensation agreement with the agency. Allegheny Software Publishers has added additional wording to the certification language of the Home Health Plan of Care. Allegheny Software Publishers is aware this additional wording in not part of the five content requirements detailed for the Certification language in 42 CFR 424.22 (a)(1)(i-v). Allegheny Software Publishers does not feel this additional wording will cause any issues as it continues to ensure the five content requirements are present, but will assist agencies with positive payment determinations during targeted probes or medical record reviews.
As per regulation 42 CFR 424.22 (d) Limitation of Performance of Physician Certification and Plan of Care functions, a physician who has a financial relationship as defined by 42 CFR 411.354 with a Home health agency may not certify, recertify, conduct a Face to Face encounter or establish a patient Plan of Care.
Agencies still need to comply with regulation 42 CFR 411.354 in Subpart J relating to Financial Relationship between Physicians and Entities furnishing designated health Services, Financial relationship, compensation and ownership or investment interest.