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Allowed Practitioners

Recently, CMS issued a revision to a previously released transmittal—Change Request 12615.  The subject was an update to Chapter 7, Home Health Services in the Medicare Benefit Policy Manual.  One of the items included in this transmittal was a clarification of the rule change from the CARES Act which allows clinical nurse specialists, physician’s assistants,…

Recently, CMS issued a revision to a previously released transmittal—Change Request 12615.  The subject was an update to Chapter 7, Home Health Services in the Medicare Benefit Policy Manual.  One of the items included in this transmittal was a clarification of the rule change from the CARES Act which allows clinical nurse specialists, physician’s assistants, and nurse practitioners to certify eligibility and order services under the Medicare home health benefit.  The explanation of “allowed practitioners” now makes it clear that nurse practitioners and clinical nurse specialists who work as allowed practitioners must work in collaboration with a physician when state law does not allow the practitioner to work independently without  a written collaborative agreement or supervision from a physician.  CMS states, “In the absence of State law governing collaboration, collaboration is to be evidenced by NPs documenting their scope of practice in the medical record, and indicating the relationships that they have with physicians to deal with issues outside their scope of practice”.  Home health agencies should review their state regulations regarding these specific nursing practices.  Ensure allowed practitioners who are certifying patient eligibility and ordering services understand their responsibilities for documentation.  Implementation for this requirement is May 26, 2022.