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CMS-1403-FC
the physicians that furnish these services, to determine
goals and assess options. Commenters further suggested
that goals and options could include revising the procedure
codes used for billing, assessing the current RVUs, and
establishing documentation expectations.
Some commenters suggested that payments to physicians
for certifying and recertifying HH POCs should be
restructured to provide incentives for greater physician
involvement, to include personally seeing the patients.
Specifically, some commenters suggested adding different
payments for the varying levels of physician involvement in
the certification and recertification of HH POCs. Other
commenters urged CMS to consider how home telehealth can be
employed to a greater degree to increase input of clinical
information directly to physicians in lieu of face-to-face
contact.
Other commenters suggested that we actively support
amending the Medicare statute to allow nurse practitioners
(NPs) to certify and recertify HH POCs. Some commenters
suggested that we actively support demonstrations and
legislative proposals to build on the concept of merging
home care with primary care under a single care management
entity for persons in the advances stages of chronic
illnesses. Other commenters suggested that payment to
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