The AMA vehemently opposes implementation of the certification requirement. It is completely inappropriate for physicians to have the responsibility of meeting the proposed certification requirement. The physician's role in providing home health care to patients is to establish a plan of care for a patient and to approve and certify the medical necessity for such care. This aspect of patient care is within the physician's expertise, which includes establishing and overseeing the plan of home care, determining medical necessity, and reviewing quality and outcome of care for these patients. It would be inappropriate for physicians to have the further responsibility of essentially auditing the HHA's billing records, i.e. for determining and verifying the accuracy of the HHA's HHRG coding practices.
Physicians provide medical care.
They are not auditors nor law enforcement officials. In addition, it is not feasible for physicians to approve the HHRG, and the AMA is unclear how the proposed system could work. Physicians are not on-site at the HHA and cannot adequately monitor the HHA HHRG designation. Moreover, physicians are not trained in the HHA claims reporting system and do not have additional time outside of their patient care responsibilities to learn this system. Physicians already are required to maintain knowledge of and comply with thousands of pages of massive Medicare regulatory requirements.