Physician’s Signature on the Plan of Care Form

By Beth Foster, RN, BA, CPHQ, CEHCH

Physician’s Signature on the Plan of Care Form

This story started in January – Behind the scene OCHCH’s Regulatory Affairs Director, Beth Foster, has been in discussions with Palmetto off and on since January 10, 2020. Since that time Foster received two calls from Palmetto representatives to discuss with them all the reasons to accept the physician signed POC page.

The “straw that broke the camel’s back” occurred during the February 5, 2020 Palmetto GBA RCD Monthly provider call when two different Palmetto staff were presenting conflicting requirements about the physician’s signature on every page or one page of the Plan of Care form, and also not having all pages faxed back from the certifying physician. One Palmetto staff stated, “We do not require that.” Then another stated that “there needs to be a fax thread or a cover sheet to prove that physician read all pages.”

I e-mailed a question to the Palmetto staff asking, “Why is this being required, when not even the state survey agencies that have oversight over the Medicare certified HHAs have no such requirement?”

To make a long story short OCHCH had input into the updated article titled Responding to a Home Health Additional Documentation Request (ADR). Palmetto GBA has revised an article that was already in their website to include a specific mention to the pagination on the Plan of Care (i.e. page 1 of 4, page 2 of 4, page 3 of 4, and page 4 of 4). There are several other edits made to the article to refresh it as it is an article that Palmetto GBA has had out there for quite some time. Hopefully this article will help with some of the questions HHA providers have sent to Palmetto GBA regarding the physician’s signature on the Plan of Care form.

Under the “Plan of Care and Certification/Recertification” section the article states:

“If the physician signature is not on every page of the plan of care it must be clear that all pages of the plan of care are associated. For example, each page of the plan of care contains the page number and the total number of pages, such as ‘Page 1 of 4,’ ‘Page 2 of 4,’ etc.”

Just to make sure, I asked Palmetto the following question: “I want to make sure that the medical reviewers will accept not only the first (or last) page (i.e. page 1 of 4 or it could be page 4 of 4) POC signed/dated by the physician, but also the rest of the POC pages the HHA has in the patient’s medical record.

Palmetto GBA representative responded: “Yes, that is correct.”