HCA still pushing for confirmation that state regulations will likewise recognize new practitioner allowances being granted by CMS
Section 3708 of the CARES Act allows Nurse Practitioners (NPs), certified Clinical Nurse Specialists (CNSs), and Physician Assistants (PAs) to certify beneficiaries for eligibility under the Medicare home health benefit and oversee their plan of care — a permanent change that will continue after the public health emergency.
The U.S. Centers for Medicare and Medicaid Services (CMS) has now announced that these non-physician practitioners may bill existing codes effective for claims with dates of service on or after March 1, 2020. CMS will revise the descriptors of these three codes at a later date to include the non-physician practitioner specialties. The codes are as follows:
- G0179: Physician re-certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care.
- G0180: Physician certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care.
- G0181: Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans.
While CMS is opening up these permanent NPP authorization allowances federally, HCA is still seeking clarification on whether the state is likewise following suit with overlapping authorizations, including whether the state will permit all three of the CMS-recognized NPP disciplines to issue orders: nurse practitioners, physician assistants and clinical nurse specialists.
HCA is soon expecting a Dear Administrator Letter or other state guidance in response to our call for clarification and confirmation from the state.