On April 6, 2012, CMS issued a Survey and Certification Transmittal stating that when a Home Health Agency (“HHA”) deactivates its provider number (the provider number is now referred to as the CMS Certification Number or CCN), the HHA must be surveyed for compliance with the CMS Conditions of Participation (CoPs) for HHA’s if the HHA desires to reactivate its provider number. Deactivation of a provider number generally occurs if the HHA does not file claims for 12 consecutive months.
The requirement that a CoP survey must be conducted when the HHA reactivates its provider number dates back to an amemdment to the Home Health Prospective Payment System. This final rule amended 42 C.F.R. 424.50(b)(3) to require as of January 1, 2010 that the HHA be surveyed before reactivating its provider number. The survey is considered a Tier IV re-certification survey with a note that the survey is being conducted for the purpose of reactivating a provider number. The HHA will retain its current provider number since the HHA’s provider agreement s remains in effect even though the HHA deactivated its provider number. The re-certifaction survey will be conducted by the state survey agency or accrediting organization if the HHA is accredited. It is the responsibility of the HHA to notify the state survey agency or accrediting organization of its need to be surveyed.
The effective date of the Survey and Certification Transmittal begins immediately.
Should you have any questions, please contact:
Todd Selby at 317.977.1440 or tselby@wp.hallrender.com; or
David Bufford at 502.568.9368 or dbufford@wp.hallrender.com,
or your regular Hall Render attorney.