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<strong>CMS</strong>-1403-FC<br />

there exists a vast array of differing levels of physician<br />

involvement in the certification and recertification of<br />

home health POCs. We continue to believe that the active<br />

involvement of the physician (to include “in-person”<br />

contact with the patient) in the certification,<br />

recertification, and review of the home health POC is<br />

essential for delivery of high quality home health services<br />

to Medicare beneficiaries.<br />

To that end, we offered different policy options and<br />

solicited the public for comment on those options in an<br />

effort to gather more information on this issue, and any<br />

other possible underlying issues that may exist.<br />

response.<br />

The following is a summary of the comments and our<br />

Comment: Most commenters suggested that we leave our<br />

current policies and payment to physicians unchanged, at<br />

least until the further analysis is completed. To that<br />

end, it was suggested by commenters that we continue to<br />

study the role of the physician in home care and determine<br />

which factors enhance a physician’s ability to conduct<br />

oversight activities, ensure appropriateness of care, and<br />

work collaboratively with home health agencies without<br />

further burdening Medicare beneficiaries. Commenters urged<br />

<strong>CMS</strong> to engage with industry organizations that represent<br />

722

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