Home Health Plans of Care: NPs, CNSs and PAs Allowed to Certify

Section 3708 of the Coronavirus Aid, Relief and Economic Security (CARES) Act (Pub. L. No. 116-136) amended sections 1814(a) and 1835(a) of the Social Security Act to allow 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. This is a permanent change that will continue after the Public Health Emergency.

Effective for billing periods with dates of service on or after March 1, 2020, these nonphysician practitioners may conduct the following notwithstanding each state’s individual scope of practice, which may be submitted on professional (Part B) claims.

  • G0179: Physician recertification 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’s 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’s 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

The descriptors of the three codes will be revised at a later date to include the nonphysician practitioner specialties.

Palmetto GBA encourages providers and practitioners to verify these services are provided in accordance with the state's scope of practice. Billing periods that utilize nonphysician practitioners not in accordance with the state’s defined scope of practice may result in claim denials or non-affirmations.

Please remember to enroll in PECOS for updated contact information.

Please see the
MLN Connects newsletter dated May 7, 2020 (PDF, 199 KB), for more information.

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