CMS Pub. 100-08, ch. 6, § 6.3

SNFs

(Rev. 823; Issued: 10-05-18; Effective: 11-06-18; Implementation: 11-06-18)

The Medicare conditions of payment require a physician certification and (when specified)

recertification for SNF services. This requirement is explicitly stated in §1814(a)(2) of the

Social Security Act. 42 CFR 424.20 details the required contents of the certification and re-certifications and 42 CFR 424.11 specifies that "no specific procedures or forms are required

for certification and recertification statements," and that "the provider may adopt any method

that permits verification. The certification and recertification statements may be entered on

forms, notes, or records that the appropriate individual signs, or on a special separate form"

(emphasis added). Further, 42 CFR § 424.11(b) specifies that information contained in other

provider records, such as physicians’ progress notes, need not be repeated in the certification

or recertification statement itself. Recent decisions by administrative law judges, that CMS

believes are fully consistent with law and regulations, reinforce the need for MACs to

consider documentation in the beneficiary's medical record beyond a discrete certification or

recertification form to determine if the required elements for certification are present.

Contractors shall deny claims for failure to comply with the certification or re-certification

content requirements in 42 CFR 424.20 and not for the failure to use a separate certification

form or particular format.