Home Health & Hospice Articles by Topic: Compliance

Check your computer system configuration to reduce the risk of a breach

• Homecare Direction, Issue 10, October 11, 2019

  The multi-million dollar settlements paid by Cottage Health and Touchstone Medical Imaging reveal...

Pseudo-patients now greenlighted for aide competency evaluations

• Homecare Direction, Issue 10, October 11, 2019

  Agencies once again will be able to use pseudo-patients to conduct aide skill competency...

New discharge planning CoP for home health not as burdensome as proposed

• Homecare Direction, Issue 10, October 11, 2019

  After four years, a proposed rule and a deadline extension, CMS is finalizing conditions home...

A client wants to come into one of our branch offices for her scheduled visit. Is that acceptable?

• Homecare Q&A, Issue 9, September 23, 2019

  If the patient does in fact leave the home, the patient may nevertheless be considered homebound...

CMS proposes allowing therapy assistants to perform maintenance therapy

• Homecare Direction, Issue 9, September 4, 2019

  Home care providers should weigh options for providing more cost-effective therapy in 2020 under...

Incorporate lessons learned during CMS' Review Choice Demo as it expands to Ohio

• Homecare Direction, Issue 9, September 4, 2019

  As the Review Choice Demonstration (RCD) expands, agencies in Ohio and beyond should take note of...

As PDGM approaches, it's increasingly important to fight for hospital referrals

• Homecare Direction, Issue 9, September 4, 2019

  With the Patient-Driven Groupings Model (PDGM) launching on Jan. 1, 2020, agencies are recognizing...

Will a follow-up OASIS with a different diagnosis than the start of care (SOC) OASIS affect billing at the end of the episode?

• Homecare Q&A, Issue 8, August 26, 2019

  Yes. It’s kind of complex the way billing is going to work. If the clinician conducts a SOC...

Is it better to get a PEP on an episodes than avoiding the LUPA threshold?

• Homecare Q&A, Issue 8, August 26, 2019

  Agencies should follow whatever would be the most compliant process for the situation.

What areas are crucial for coders to be diving into right now in order to prepare for PDGM?

• Homecare Q&A, Issue 8, August 26, 2019

  It’s going to be important that coders get familiar with what a valid diagnosis is in PDGM...

CMS puts more weight on behavioral assumptions, but increases payments by 1.3%

• Homecare Direction, Issue 8, August 7, 2019

  CMS is seeking to reduce agency payments even more than expected to account for assumed behavioral...

Don't delay preparations: CMS stays on course for 2020 PDGM implementation

• Homecare Direction, Issue 8, August 7, 2019

  With a new payment model set to take effect in less than six months, agencies cannot afford to...

Take steps to avoid cash flow disruptions as CMS seeks to eliminate RAPs

• Homecare Direction, Issue 8, August 7, 2019

  Evaluate cash flow to see how your agency would perform if requests for anticipated payment (RAPs...

Should we code all diagnoses or only those affecting the plan of care?

• Homecare Q&A, Issue 7, July 29, 2019

  Unfortunately this is an instance of where we have conflicting regulations.

Is it allowable to bill without a signed consent to treat and a signed benefit form?

• Homecare Q&A, Issue 7, July 29, 2019

  Since this is a condition for payment, then the patient must give informed consent prior to...

What can be done when a nurse leaves the agency with an incomplete resumption of care (ROC) OASIS?

• Homecare Q&A, Issue 7, July 29, 2019

  As far as paperwork for your agency, you will need to see if the next qualifying clinician would...

Make sure to use CMS' tool to examine how your agency will fare under PDGM

• Homecare Direction, Issue 7, July 8, 2019

  When preparing for the Patient-Driven Groupings Model (PDGM), one crucial step agencies should...

How can intake help us avoid unspecified abnormalities of gait as a primary diagnosis?

• Homecare Q&A, Issue 6, June 28, 2019

  Intake could say to the referral source, “Does the patient have any neuropathy? Does the...

When should PDGM training with staff begin?

• Homecare Q&A, Issue 6, June 28, 2019

  I’ve been telling people to stay in today’s world, which is PPS, while balancing moving...

Take these crucial actions to ensure success during CMS' Review Choice Demo

• Homecare Direction, Issue 6, June 6, 2019

  Agencies seeking to pass CMS’ Review Choice Demonstration (RCD) with flying colors should...

CMS updates providers about hospice star ratings, OASIS-D1, PDGM

• Homecare Direction, Issue 6, June 6, 2019

  CMS is conducting data analysis to prepare for possible introduction of star ratings on Hospice...

Why aren’t patient rights citations common and will they become a bigger issue?

• Homecare Q&A, Issue 5, May 31, 2019

  There were some things in the patient rights requirements that were new, that were different.

Can you answer my question about the scope of orders?

• Homecare Q&A, Issue 5, May 31, 2019

  You have a specific question about the scope of physician orders and co-signatures.

Will the Home Health Payment Innovation Act of 2019 pass?

• Homecare Q&A, Issue 5, May 31, 2019

  There appears to be fairly strong support in the Congress to pass the bill.  

Can you provide me info on ACH measure on CASPER?

• Homecare Q&A, Issue 5, May 31, 2019

  You note that when looking at the AHC measure on CASPER, you have data that is risk-adjusted and...

Build compliance culture: stop minor issues from becoming major problems

• Homecare Direction, Issue 5, May 8, 2019

  You’ve created a compliance program, but are you getting the most out of it? A hospice or...

Why do agencies struggle on Home Health Compare with hospitalizations?

• Homecare Q&A, Issue 4, April 18, 2019

  You note agencies' struggles with hospitalizations.

Why is M1033 (Risk for hospitalization) going to be part of functional case-mix adjustments?

• Homecare Q&A, Issue 4, April 18, 2019

  You note that the importance of OASIS-D item M1033 (Risk for hospitalization) increases even more...

Thoughts on CMS' proposed rule to alleviate burden and when it will be finalized?

• Homecare Q&A, Issue 4, April 18, 2019

  A couple years ago, the new administration came in with a desire to simplify life for providers.

Can you give tips on M1860 (Ambulation/locomotion)?

• Homecare Q&A, Issue 4, April 18, 2019

  You note that your agency is preparing for PDGM.

In the coming year, how do you think survey targets will change?

• Homecare Q&A, Issue 4, April 18, 2019

  We’re going to keep seeing agencies cited for issues involving organization and...

Find the balance between preparing for PDGM and living in the current PPS world

• Homecare Direction, Issue 4, April 8, 2019

  While experts agree it’s important to start preparing now for the Patient-Driven Groupings...

Many agencies identify timely initiation of care as a key PIP for 2019

• Homecare Direction, Issue 4, April 8, 2019

  Education and communication are the keys to improving timely initiation of care for agencies...

New York '13-hour standard' for live-in caregivers again acceptable

• Homecare Direction, Issue 4, April 8, 2019

  After more than a year of legal back-and-forth, home care agencies in New York can rest easy in the...

How can we keep our eyes on the ball on hospitalizations as we move to the next PIP?

• Homecare Q&A, Issue 3, March 22, 2019

  Root cause analysis still needs to be done at every hospital transfer because agencies will be able...

What are the most common, easily fixable issues you see when it comes to agencies with high hospitalization rates in home health?

• Homecare Q&A, Issue 3, March 22, 2019

  One is going to be the scheduling aspect. Getting out to the home within 24 to 48 hours is vital.

Must PIPs include a representative of all disciplines, a physician and a consumer like the PAC?

• Homecare Q&A, Issue 3, March 22, 2019

  The revised CoPs don't give specific protocols for what a PIP must look like.

Why is Acute Care Hospitalization noteworthy for agencies outside VBP states?

• Homecare Q&A, Issue 3, March 22, 2019

  Those that are not in the value-based purchasing states really should pay attention to what...

Is the board responsible to sign off on all policies? 

• Homecare Q&A, Issue 3, March 22, 2019

  The Home Health Conditions of Participation (CoPs) require the governing body approve all policies...

How can I decrease the number of clinician missed visits? How do Medicare surveyors treat missed visits?

• Homecare Q&A, Issue 3, March 22, 2019

  Are the clinicians moving the visits to another day during the week?

Is it legal for the outpatient therapy agency to provide services in the assisted living?

• Homecare Q&A, Issue 3, March 22, 2019

  Therapy can provide Part B billing if patients are outpatient or even in their homes.

CMS suppresses RAP payments for all new home health agencies nationwide

• Homecare Direction, Issue 3, March 6, 2019

  In the short term, a new MLN Matters article announcing CMS will suppress payments associated with...

Change request gives key details about PDGM in advance of 2020 implementation

• Homecare Direction, Issue 3, March 6, 2019

  A new change request from CMS implements the policies of the Patient-Driven Groupings Model (PDGM...

Any advice for best practices to add emerging infectious diseases into emergency prep?

• Homecare Q&A, Issue 2, February 25, 2019

  You note that CMS is adding “emerging infectious diseases” to the current definition of...

I have a question about therapists submitting a list of patient medications for the nurse to review.

• Homecare Q&A, Issue 2, February 25, 2019

  You say that your agency just learned that according to the revised CoPs, in rehabilitation...

We have an issue with M2003 (Medication follow-up).

• Homecare Q&A, Issue 2, February 25, 2019

  The quality measure “drug regimen review conducted with follow-up for identified...

When a patient signs a paper form (consent for care, AOB, ABN, etc.) are we required to keep the actual signed form if we have a picture of the signed form in our electronic medical record?

• Homecare Q&A, Issue 2, February 25, 2019

  When the revised Home Health Conditions of Participation (CoPs) originally came out, there was an...

In the QAPI requirement §484.65, what does CMS mean by including the prevention and reduction of medical errors?

• Homecare Q&A, Issue 2, February 25, 2019

  We are assessing and observing if we have an issue related to medical error.

If a MSW is ordered, but the case manager does not feel it is necessary, can she just not include it on the plan of care?

• Homecare Q&A, Issue 2, February 25, 2019

  Yes, it can be omitted from the plan of care.

Reducing hospitalization rates will be a key goal for many agencies in 2019

• Homecare Direction, Issue 2, February 5, 2019

  More agencies plan to focus on improving the rate of acute care hospitalizations than any other...

What do you see as the most sensible or welcome changes under OASIS-D?

• Homecare Q&A, Issue 1, January 16, 2019

  The most welcome changes to me are the removal of those coding items, M1011 (Inpatient diagnosis...

What about the F2F requirements? Should we treat all payers the same and require the same as Medicare?

• Homecare Q&A, Issue 1, January 16, 2019

  Face to Face is a Conditions of Payment requirement and is required for Medicare and Medicaid.

Is the patient in the following scenario considered to be incontinent of stool for the M1620 question?

• Homecare Q&A, Issue 1, January 16, 2019

  This scenario is not specifically addressed in the OASIS Q&As.

What strategies would you advise rural agencies use in 2019 to help withstand the phase-out?

• Homecare Q&A, Issue 1, January 16, 2019

  You explain that your  agency is based in a rural area, and beginning this year the rural...

How should we speak with staff about shifting away from the pay-per visit model?

• Homecare Q&A, Issue 1, January 16, 2019

  You note that your agency is considering shifting away from a pay-per visit model for clinicians...

What is G1024 (Authentication) and how can agencies avoid getting cited for it?

• Homecare Q&A, Issue 1, January 16, 2019

   G1024 (Authentication) is one of the more common standard-level deficiencies in 2018.

Do agencies have a responsibility to train staff to identify whether patients are addicted to opioids?

• Homecare Q&A, Issue 1, January 16, 2019

  You asked whether agencies have a responsibility to train staff to identify whether patients are...

Year of data show agencies fared poorly in targeted probe and educate

• Homecare Direction, Issue 1, January 4, 2019

  Newly released data show a massive percentage of agencies participating in CMS’ targeted...

Experts: Blue wave drowns GOP agenda in Congress for 2019

• Homecare Direction, Issue 1, January 4, 2019

  As you might expect now that Democrats have taken control of the House and Republicans have...

What's the best advice you have for an agency that hasn't been through a demonstration like the review choice demo before?

• Homecare Q&A, Issue 17, December 17, 2018

  Choose the pre-claim option.

What led Illinois agencies' improvement in the pre-claim demo?

• Homecare Q&A, Issue 17, December 17, 2018

  Learning and implementing the feedback loop.  

Do you see hospital-based agencies being more successful under PDGM?

• Homecare Q&A, Issue 17, December 17, 2018

  Hospital-based agencies are going to have more institutional admits than community admits.  

Can you explain how partial episode payments (PEPs) will work under PDGM?

• Homecare Q&A, Issue 17, December 17, 2018

  First let’s go over how a PEP works.  

Now that CMS has finalized PDGM, agencies must begin preparing immediately

• Homecare Direction, Issue 12, December 5, 2018

  Agencies that wait until the last minute to prepare for the Patient-Driven Groupings Model (PDGM...

Our agency is considering investing in telehealth solutions. Do you have any recommendations for important questions to ask of potential vendors?

• Homecare Q&A, Issue 16, November 20, 2018

  Here are some of the questions to ask.  

What's roughly the average amount of time it should take a home health agency to submit a bill under PPS (from the day of admission)?

• Homecare Q&A, Issue 16, November 20, 2018

  For a final claim, (which is sent at the end of the 60-day period), there should be enough time to...

For commercial payers, is it necessary to perform a recertification visit within the required five-day window?

• Homecare Q&A, Issue 16, November 20, 2018

  All payers must follow the Conditions of Participation, which require an update to the...

My agency appears to be losing a significant amount of money under PDGM. What strategies would you recommend I take?

• Homecare Q&A, Issue 16, November 20, 2018

  PDGM is designed to be budget neutral, but the impact on payment depends on type of provider and...

When it comes to the CoPs, what kinds of issues arise with policies?

• Homecare Q&A, Issue 16, November 20, 2018

  Often policies are written very well.

Do per-day sanctions begin when a surveyor finds a deficiency or do they begin on the date in the medical record when the deficiency occurred?

• Homecare Q&A, Issue 16, November 20, 2018

  I’ve seen it go both ways.

How do you expect enforcement from surveyors to change over the next year?

• Homecare Q&A, Issue 16, November 20, 2018

  It might not change. It might just intensify.

For some choices in review choice demo, there are no takebacks

• Homecare Direction, Issue 11, November 5, 2018

  While agencies have choices when it comes to which claim review option to select for CMS&rsquo...

I saw that CMS recently posted an updated Public Use File (PUF). Could you explain why this is important and what it's for?

• Homecare Q&A, Issue 15, October 19, 2018

  The public use file is a file that is used by policymakers and researchers that review the...

Settlement reinforces need to act when ineligible care is alleged

• Homecare Direction, Issue 10, October 4, 2018

  Ensure sound protocols are in place for how to respond when an employee alerts you that your...

Proposed rule seeks to change CoPs, eliminating burden for agencies

• Homecare Direction, Issue 10, October 4, 2018

  CMS is proposing to eliminate three requirements it has deemed “burdensome” for home...

Long-awaited final interpretive guidelines provide clarification about the revised CoPs

• Homecare Direction, Issue 10, October 4, 2018

  Nearly eight months after the revised Home Health Conditions of Participation (CoPs) took effect...

What should I do if I take on a patient with a diagnosis that fits within one of the six clinical groups under PDGM?

• Homecare Q&A, Issue 14, September 21, 2018

  The 2019 proposed PPS rule references this concern in several areas.

What recommendations/strategies do you have for gathering documentation fast so we can bill quicker under PDGM?

• Homecare Q&A, Issue 14, September 21, 2018

  CMS estimates the median length of days for request for anticipated payment (RAP) submission is 12...

Is a home health face-to-face visit required for Medicare Advantage plans?

• Homecare Q&A, Issue 14, September 21, 2018

  CMS doesn't require Medicare Advantage plans to have a face-to-face document for home health.

In the following scenario, should my agency write an order stating the patient is in compliance of taking medications as ordered?

• Homecare Q&A, Issue 14, September 21, 2018

  In the scenario you describe, your agency admitted a patient when she was discharged home from the...

In this scenario, is my agency required to conduct a transfer then ROC, or not?

• Homecare Q&A, Issue 14, September 21, 2018

  In the scenario you discuss, your agency had a patient that was a full admission to the hospital.

If my agency makes drastic changes to adapt to PDGM, might CMS target us as though we're committing fraud?

• Homecare Q&A, Issue 14, September 21, 2018

  At this point, I would suggest you don't do anything drastic.

Explain CMS' moratoria for agencies in certain areas and how the demonstration recently changed.

• Homecare Q&A, Issue 14, September 21, 2018

  The demonstration gives an opportunity for providers and suppliers otherwise subject to the...

Is it legal to have one of our home health patients pay the same CNA privately on the days the patient is not being seen under the home health benefit?

• Homecare Q&A, Issue 13, September 4, 2018

  Does the patient require hours your agency is not providing, but should be?

Can you give pointers on "environmental cleaning and disinfection" as mentioned in draft guidelines for the revised CoPs?

• Homecare Q&A, Issue 13, September 4, 2018

  You should have a policy in place that describes things like a bag barrier and how to clean your...

What advice do you have about how an agency could improve when it comes to timely initiation of care?

• Homecare Q&A, Issue 13, September 4, 2018

  This is a difficult question to answer, not knowing your agency processes. But there are several...

Can you explain in this scenario whether our surveyor is correct and what our agency should do?

• Homecare Q&A, Issue 13, September 4, 2018

  In the scenario you discuss, your agency is in Indiana and are currently going through a federal...

Is it acceptable for a physician to sign a home health plan of care when he/she is not the physician named in the locator box on the plan of care?

• Homecare Q&A, Issue 13, September 4, 2018

  In the scenario you discuss, the signing physician is also the MD certifying the patient for home...

We have a conflict occurring related to documentation and billing. Can you help?

• Homecare Q&A, Issue 13, September 4, 2018

  In the scenario you discuss, your agency’s billing department reviews documentation before...

What impact will there be from CMS' proposal for agencies to list remote patient monitoring on cost reports?

• Homecare Q&A, Issue 13, September 4, 2018

  One portion of the proposed PPS rule seeks changes to have agencies list remote patient monitoring...

Are there things we should do differently with claims to prepare for PDGM?

• Homecare Q&A, Issue 12, July 25, 2018

  PDGM is going to be such a rapid cycle flurry of action.

What's an example of a billing aberrancy that's prompting contractors to target agencies in targeted probe-and-educate reviews?

• Homecare Q&A, Issue 12, July 25, 2018

  We see inappropriate recertifications all over the place.

Looking for some guidance on a patient with a closed stage IV pressure ulcer who now presents with non-blanchable redness to the same injury site but skin is intact.

• Homecare Q&A, Issue 12, July 25, 2018

  Once the wound is fully granulated and the wound surface is covered with epithelial tissue, the...

How should I act in the following scenario involving power of attorney (POA)?

• Homecare Q&A, Issue 12, July 25, 2018

  First determine if the POA is medical and if the patient is incapacitated.

Would M2001 be accurate if marked "No - no issues found" in a scenario I'll describe below?

• Homecare Q&A, Issue 12, July 25, 2018

  It is up to clinicians to determine, in their clinical judgement, if the omission is a clinically...

Can advanced practice nurses (APNs) sign orders for home health patients?

• Homecare Q&A, Issue 12, July 25, 2018

  APRAs cannot write orders for a plan of care or subsequent verbal orders.

If a patient requires assistance to complete ADLs but is independent with all gait and mobility, can the person still be considered homebound per Medicare guidelines due to the taxing effort of getting ready to leave the home?

• Homecare Q&A, Issue 11, July 15, 2018

  This question cannot be answered, as each eligibility is established with each particular patient.

We have a policy that the patient must sign the tablet (EMR) post-visit. If a patient lives in an ALF and has dementia, is it OK to ask the patient to sign?

• Homecare Q&A, Issue 11, July 15, 2018

  There is no CMS regulation to have the EMR/tablet/daily visit record signed.

What if the PT and OT are ordered at SOC and the PT does an evaluation and no further treatments are ordered/planned but the OT does an eval and stays in alone for the episode?

• Homecare Q&A, Issue 11, July 15, 2018

  Per §1814(a)(2)(C) and §1835(a)(2)(A) of the Social Security Act, the patient must be in...

How would you code a hematoma in the following situation?

• Homecare Q&A, Issue 11, July 15, 2018

  Your agency should call the physician and see if this has now elevated to an open wound.  

How do you code a wound in a specific situation involving venous insufficiency?

• Homecare Q&A, Issue 11, July 15, 2018

  In the specific scenario you describe, it would continue to be coded as a trauma wound that is...

Our agency has had difficulty getting documentation for the F2F requirement from certain physicians. Should we deny the referrals?

• Homecare Q&A, Issue 11, July 15, 2018

  Denying a referral should be a determination based on agency policy and physician...

Review your emergency preparedness - it's a top target on surveys in 2018

• Homecare Direction, Issue 7, July 2, 2018

  Among the top 12 standard-level deficiencies in home health thus far in 2018, seven involve issues...

Prioritize areas for improvement, have your next target QAPI project identified

• Homecare Direction, Issue 7, June 29, 2018

  It’s great if your agency’s performance improvement project (PIP) under QAPI is up and...

Is it OK to accept a doctor's signature on one page of a multi-page order as being signed?

• Homecare Q&A, Issue 10, June 11, 2018

  It is important for the pages of the plan of care to be clearly numbered if there is more than one...

Is it necessary to document the RVVO piece of a verbal order?

• Homecare Q&A, Issue 10, June 11, 2018

  The Joint Commission (TJC) includes a requirement under the Provision of Care, Treatment and...

Can we send an LPN to have consents signed and do wound care at SOC if the RN can’t come timely?

• Homecare Q&A, Issue 10, June 11, 2018

  PNs - along with occupational and physical therapy assistants - aren't qualified to establish the...

How should we handle cases when there are diagnoses presented on the assessment that weren’t in physcian documentation?

• Homecare Q&A, Issue 10, June 11, 2018

  Diagnoses listed in M1011 (Inpatient diagnosis), M1021 (Primary diagnosis) and M1023 (Other...

What advice could you provide when it comes to responding to the two new J items proposed for OASIS-D?

• Homecare Q&A, Issue 10, June 11, 2018

  Review what instruction have provided for J1900C in the MDS 3.0 Resident Assessment Manual for...

What suggestions do you have for how agencies can achieve success on pre- or post-payment reviews?

• Homecare Q&A, Issue 10, June 11, 2018

  Agencies need to begin now to ensure that they are getting valid face-to-face documentation with...

When is it necessary to conduct an oxygen safety assessment for home health patients?

• Homecare Q&A, Issue 10, June 11, 2018

  All O2 patients need to at least be assessed on a comprehensive assessment for safety.

CMS surveyors appear to be targeting issues involving aide training, supervision

• Homecare Direction, Issue 6, June 4, 2018

  Initial survey results following the implementation of the revised Home Health Conditions of...

Say an agency is starting from scratch on the process of responding to ADRs. What is the first thing that should be put in place?

• Homecare Q&A, Issue 9, May 12, 2018

  First off, know on the front end that the biller is looking for those requested records. Ensure...

Do we need to enumerate one by one the patient?s rights over the phone to the legal representative?

• Homecare Q&A, Issue 9, May 12, 2018

  This can be done by electronic methods.

What is the best way to comply with the patient rights requirement?

• Homecare Q&A, Issue 9, May 12, 2018

  Several agencies have provided this information through a secure portal either through their EMR or...

Could you share some examples of things that might flag agencies as outliers in billing when it comes to the targeted probe-and-educate review?

• Homecare Q&A, Issue 9, May 12, 2018

  The purpose of the targeted probe-and-educate review is to reduce improper payments by auditing...

When it comes to the face to face requirement, what can/should be done and documented differently when the visit is performed by a nurse practitioner or a physician's assistant?

• Homecare Q&A, Issue 9, May 12, 2018

  Documentation from the non-physician practitioner (NPP) must meet all the required elements for the...

Do agencies have the right to tell patients we require a written request for patient records if the patient asks for a record over the phone?

• Homecare Q&A, Issue 9, May 12, 2018

  Agencies may require patients to make a written request for copies of the medical record. This is a...

Early survey results show individualized plans of care are a major target

• Homecare Direction, Issue 5, May 2, 2018

  Break your agency’s clinicians of their mentality to rely solely on generic language or...

Early survey results reveal patient rights as target areas under revised CoPs

• Homecare Direction, Issue 5, May 2, 2018

  Key target areas include informing patients about visit frequency and about explaining financial...

How likely is that CMS adopts a payment model other than the Home Health Groupings Model? And other than there being budget neutrality this time around, what aspects might change from what was proposed last year?

• Homecare Q&A, Issue 8, April 17, 2018

  We?re going to see something along the lines of the Home Health Groupings Model.

Does eliminating therapy thresholds under a revised payment model such as HHGM mean that regardless of how many therapy visits an agency provides, payments will remain the same?

• Homecare Q&A, Issue 8, April 17, 2018

  It remains to be seen what the new payment model will look like.

For hospice, can activity done over the phone with a patient by a chaplain or social worker be considered a visit if the call is extensive and covers several items from the plan of care (POC)? What about for the purposes of meeting HIS quality measures?

• Homecare Q&A, Issue 8, April 17, 2018

  No conversation on the phone can be billable, as is the same for HIS quality measures.

How do we count the 14-day certified home health aide supervisory visit? Is the day of the visit day 1 or is the day after the visit day 1?

• Homecare Q&A, Issue 8, April 17, 2018

  The supervisory visits need to be no less frequently than every 14 days from the date of the first...

If a therapy case patient is recertified, a new evaluation is done before beginning the new episode. Does this mean that no functional reassessment is needed anymore since an evaluation was done?

• Homecare Q&A, Issue 8, April 17, 2018

  In most agencies with an electronic health records (EHR) system, the therapist completes a...

Take better care of patients with hypertension diagnosis to avoid MAC scrutiny

• Homecare Direction, Issue 4, April 12, 2018

  Thoroughly examine clinicians’ documen-tation — and ensure it’s detailed...

Ensure aides conduct competency testing on patients or take a bath on surveys

• Homecare Direction, Issue 4, April 12, 2018

  Take steps to ensure the small pool of home health patients you have who can or do bathe would...

New CMS transmittal explains how rural add-on payments will be processed

• Homecare Direction, Issue 4, April 12, 2018

  Rural agencies might have to wait a while before they get 3% add-on payments for claims submitted...

Train intake to gather more detail, ensure patient rights process is efficient

• Homecare Direction, Issue 4, April 12, 2018

  To help comply with the new patient rights requirements in the revised Home Health Conditions of...

New online training for surveyors highlights the importance of a detailed plan of care

• Homecare Direction, Issue 3, March 29, 2018

  CMS’ newly posted surveyor training reiterates the need for home health agencies to ensure...

Reminder for hospices: Submit timely HIS and CAHPS data

• Homecare E-News, Issue 13, March 26, 2018

  To comply with the Hospice QRP (HQRP) requirements, hospices must successfully submit timely...

MedPAC--yet again--recommends 5% home health payment reductions

• Homecare E-News, Issue 13, March 26, 2018

  The Medicare Payment Advisory Commission (MedPAC) is once again recommending a 5% Medicare payment...

Consider these 9 ways to avoid the hazards of an OSHA investigation

• Homecare Direction, Issue 3, March 26, 2018

  The lack of an appointed head of the Occupational Safe-ty and Health Administration (OSHA) has...

MedPAC encourages Medicare beneficiaries to use higher-quality PAC providers

• Homecare E-News, Issue 12, March 19, 2018

  During the Medicare Payment Advisory Commission’s (MedPAC) public meeting on Thursday, March...

IMPACT Act, improving care coordination special open door forum planned March 28

• Homecare E-News, Issue 12, March 19, 2018

  Learn about the development and testing of standardized patient assessment data elements mandated...

New targeted probe info shows need to scrutinize therapists' documentation

• Homecare Direction, Issue 3, March 19, 2018

  Conduct a quality audit of documentation your therapists submit. CMS’ targeted...

How can we better collaborate on OASIS?

• Homecare Q&A, Issue 6, March 17, 2018

  Agencies must abide by certain regulations in order to participate in the Medicare program, as...

We are being told that the patient needs to be involved in the case conferences and documented as such...

• Homecare Q&A, Issue 6, March 17, 2018

  Care coordination is included in the CoP 484.60-

New OIG report highlights vulnerability in how home health surveys are conducted

• Homecare E-News, Issue 11, March 12, 2018

  A new study from the HHS Office of Inspector General (OIG) shows that some of the patient lists...

Improve on medication management in your performance improvement project

• Homecare Direction, Issue 3, March 12, 2018

  Agencies gearing up for the performance improvement project (PIP) requirement under the revised...

What should we have done to help us comply with the new CoPs?

• Homecare Q&A, Issue 5, March 5, 2018

  If you haven’t done so already, do the following to help your agency tackle compliance with...

For OASIS items where a dash is a valid response, should a dash be used on the discharge OASIS, or should the item be answered based on findings from that last visit?

• Homecare Q&A, Issue 5, March 5, 2018

  AIn the case of an unexpected discharge, the last qualified clinician to see the patient should...

In regards to the probe-and-educate review, what will Medicare Audit Contractors (MAC) target?

• Homecare Q&A, Issue 5, March 5, 2018

  In CMS’ targeted probe-and-educate review, MACs will send ADRs to agencies that...

Home Health Quality Reporting Program: Revised logic for the Timely Initiation of Care measure

• Homecare E-News, Issue 10, March 5, 2018

  The Medicare Conditions of Participation (CoPs) for home health agencies that became effective...

Tip: Review the Statement of Deficiencies carefully

• Homecare E-News, Issue 9, February 26, 2018

  After a CMS survey, the home health agency administrator, clinical manager, and any other key...

Avoid HIPAA violations: Get signed consent before texting with patients via SMS

• Homecare Direction, Issue 2, February 23, 2018

  Agencies must take extra precautions if they want to send texts to patients the standard way...

President Trump signs bill that creates new home health payment model

• Homecare E-News, Issue 7, February 12, 2018

  On Friday, February 9, President Trump signed into law a bill designed to keep the federal...

CMS extends moratoria on new home health agencies in 6 metro areas

• Homecare E-News, Issue 6, February 5, 2018

  CMS has once again extended its moratoria on new home health agencies and new branches of existing...

CMS provides surveyors a high-level overview of the revised Home Health CoPs

• Homecare Direction, Issue 2, February 5, 2018

  Experts fear a lack of detailed surveyor training from CMS on the revised Home Health Conditions...

VA, HHS announce partnership to strengthen prevention of fraud, waste and abuse efforts

• Homecare E-News, Issue 5, January 29, 2018

  On January 23, the U.S. Department of Veterans Affairs (VA) and HHS announced a partnership to...

Should we be using the draft interpretive guidelines for compliance?

• Homecare Q&A, Issue 2, January 17, 2018

  You should review the final CoPs and the draft interpretive guidelines.

Improve documentation, avoid pitfalls ahead of tar-geted probe-and-educate review

• Homecare Direction, Issue 1, January 15, 2018

  Between the cost of denials and additional staffing expenses to cover the time in-volved in...

CoPs will impact operations, financials more than any other requirement in 2018

• Homecare Direction, Issue 1, January 8, 2018

  Within the revised Home Health Condi-tions of Participation (CoP) slated to take effect January...

CHAP announces CMS has approved 2018 standards that comply with revised CoPs

• Homecare E-News, Issue 2, January 8, 2018

  CMS has approved the 2018 standards set forth by the home health accrediting body Community Health...

CMS: CoPs' effective date won't change regardless of when final IGs are released

• Homecare E-News, Issue 2, January 8, 2018

  The final interpretive guidelines for the revised Home Health Conditions of Participation (CoPs...

How can we perform a mock survey?

• Homecare Q&A, Issue 1, January 3, 2018

  If an agency decides to perform a mock survey itself, it should use the Conditions of...

DOL appeals ruling that invalidated white-collar exemption changes

• Homecare E-News, Issue 49, December 22, 2017

  The Department of Labor (DOL) recently decided to appeal a ruling that effectively ended changes to...

Understanding the need for translation services ? required in the CoPs

• Homecare E-News, Issue 48, December 18, 2017

  When examining the new draft guidelines for the revised Home Health Conditions of Participation...

What documentation should we have for QAPI?

• Homecare Q&A, Issue 24, December 17, 2017

  The documentation surrounding your QAPI program should include:

How can I effectively audit and monitor risk areas of my agency?

• Homecare Q&A, Issue 24, December 17, 2017

  With the myriad of responsibilities a home health administrator must discharge each day, auditing...

New OIG report spotlights personal care services for fraud

• Homecare E-News, Issue 47, December 11, 2017

  A December 2017 OIG report details how personal care services (PCS) have risen in Medicaid fraud...

Prepare for new CoPs: Draft interpretive guidelines for the CoPs answer some questions, create others

• Homecare Direction, Issue 12, December 11, 2017

  CMS’ long-awaited draft version of the interpretive guidelines for the revised Home Health...

CJR localities halved; hip fracture episode payment model eliminated

• Homecare E-News, Issue 46, December 4, 2017

  CMS has finalized its plan to cancel four mandatory episode payment models for common cardiac and...

CMS will not move forward with Home Health Groupings Model in 2019

• Homecare Direction, Issue 12, December 4, 2017

  Actions that home health agencies and advocacy or-ganizations took to combat CMS’ proposed...

How do we challenge our survey?

• Homecare Q&A, Issue 23, December 1, 2017

  Regardless of whether you determine to challenge a survey, the Plan of Correction must be...

We can't seem to get our digitized Medicare forms to exactly match the paper forms' font or format. Would these differences make us out of compliance on those forms?

• Homecare Q&A, Issue 23, December 1, 2017

  There are specific formatting requirements for each of the forms. Below are the individual...

CMS releases new guidance about subunits

• Homecare E-News, Issue 45, November 27, 2017

  CMS has issued new guidance that explains how agencies can go about converting subunits to...

We received our Statement of Deficiencies from CMS. What do we do next?

• Homecare Q&A, Issue 22, November 17, 2017

  The administrator, clinical manager, and any other key personnel should begin reviewing the...

TJC approves revised standards in advance of CMS' emergency prep requirement

• Homecare E-News, Issue 43, November 13, 2017

  After CMS review, The Joint Commission has finally prepublished revisions to the Emergency...

Update coordination of care, plan of care practices to comply with new CoPs

• Homecare Direction, Issue 11, November 2, 2017

  Restructure clinical managers’ positions so they function more like case managers. Doing so...

How do we identify a new ADR in hospice?

• Homecare Q&A, Issue 21, November 2, 2017

  MACs use the Fiscal Intermediary Standard System (FISS) to process Medicare Part A claims...

Is there a regulation that states that RNs cannot trim the toenails of a patient with diabetes?

• Homecare Q&A, Issue 21, November 2, 2017

  A nurse should be skilled in cutting toenails, but because of the increased risk of liability if...

CMS decides not to move forward with Home Health Groupings Model in 2019

• Homecare E-News, Issue 42, November 2, 2017

  Agencies can breathe a deep sigh of relief. CMS won’t launch its drastically revised home...

NAHC attendees receive details about targeted re-views and odds HHGM will happen

• Homecare Direction, Issue 11, November 1, 2017

  The big buzz at the National Association for Home Care & Hospice (NAHC) an-nual conference in...

NAHC interim president: Odds of HHGM happening in 2019 are 50/50

• Homecare E-News, Issue 40, October 23, 2017

  The odds of the home health industry avoiding the Home Health Groupings Model in 2019 have...

How can we prevent readmissions related to pain?

• Homecare Q&A, Issue 20, October 17, 2017

  Have clinicians follow up the next day when patients have a change in pain medications or...

Where is it specifically written that an NP or a PA cannot sign homecare orders?

• Homecare Q&A, Issue 20, October 17, 2017

  There is no language specifically stating an NP or PA cannot give orders. Rather, the rules...

CHAP now approved for California

• Homecare E-News, Issue 39, October 16, 2017

  Community Health Accreditation Partner (CHAP) is now an approved accreditation organization to...

New Medicare card design, fact sheet released by CMS

• Homecare E-News, Issue 38, October 9, 2017

  As part of ongoing efforts to raise awareness about the upcoming change to Medicare numbers and...

If a patient has an established stoma and cares for it independently (the agency is not providing any care), does stoma care need to be included on the 485/plan of care?

• Homecare Q&A, Issue 19, October 3, 2017

  If the agency is not performing any care for the stoma (including any assessment, etc.) then you...

We are wondering if an OT can discharge a patient if he or she is the last discipline in? Can the OT do the discharge OASIS or a transfer OASIS?

• Homecare Q&A, Issue 19, October 3, 2017

  Yes, the OT can perform a discharge, or transfer, or any other OASIS after the SOC.

Is it OK to accept a physician order that is left on voice mail (if the required elements are present such as physician name, patient name/date of birth, etc)?

• Homecare Q&A, Issue 19, October 3, 2017

  This is not specifically addressed in the CoPs. The closest thing that would apply would be the...

If I was to leave this job, do I still qualify as an administrator for home health under the new home health CoPs or am I just grand fathered in under the old rule because I have held this position (my current position)?

• Homecare Q&A, Issue 19, October 3, 2017

  Yes, the personnel qualification requirements for HHA administrators at §484.115(a) will...

Protect patients during hurricanes by identifying their need for immediate care

• Homecare Direction, Issue 10, October 2, 2017

  The way Texas and Florida agencies reacted to the recent catastrophic hurricanes should serve as a...

Emergency prep tip: Pay attention to patients' DME needs

• Homecare E-News, Issue 36, September 25, 2017

  In advance of a disaster such as a hurricane, also consider whether each patient has necessary...

What should we do to better handle Additional Development Requests (ADR)?

• Homecare Q&A, Issue 18, September 19, 2017

  Here’s how to improve on ADRs:

Tip: Follow policy on staff discipline and discharge

• Homecare E-News, Issue 35, September 18, 2017

  The agency’s policies and procedures will include a discipline and discharge policy. It is...

Coding corner: FY 2018 coding guide-lines: "In" will be equivalent to "with" starting October 1

• Homecare Direction, Issue 9, September 18, 2017

  Conditions linked in the Alphabetic Index by the word “in” should be considered...

What should our agency be aware of during hurricane season?

• Homecare Q&A, Issue 18, September 17, 2017

  Excellent question, given the active season we’ve been having. You must comply with...

Declaration of Public Health Emergency for United States Virgin Islands, Commonwealth of Puerto Rico and State of Florida, CMS waivers enacted

• Homecare E-News, Issue 34, September 11, 2017

  The President declared a state of emergency for the United States Virgin Islands, Commonwealth of...

How do we support the decision to discharge if the patient resumes services?

• Homecare Q&A, Issue 17, August 31, 2017

  If an agency discharges a patient and that patient resumes services, there may be questions about...

What happens when a CMS survey begins?

• Homecare Q&A, Issue 17, August 31, 2017

  The moment an HHA considers to be the start of the survey is when the surveyor arrives...

How do we go about an admission that was visited only by a nurse during start of care then transferred to the hospital?

• Homecare Q&A, Issue 17, August 31, 2017

  Q46.1. If we admit a Medicare patient to our home health agency and complete a SOC...

We use a set of hospice standing orders when a patient is admitted to hospice. How can we show individualization with this, in order to comply with regulations?

• Homecare Q&A, Issue 17, August 31, 2017

  Interpretive Guidelines §418.56(c)(2) state...

CMS releases written Q&As from May provider training

• Homecare E-News, Issue 33, August 28, 2017

  CMS has released Q&As in writing on its Home Health Quality Reporting Training website. The...

MAC spokesman: Probe-and-educate review has high error rate, could expand

• Homecare Direction, Issue 8, August 25, 2017

  Two months after CMS said there was no plan for another round of the probe-and-educate review for...

Homecare Q&A, August 17, 2017

• Homecare Q&A, Issue 16, August 17, 2017

  Homecare Q&A, August 17, 2017

Create a patient rights verification form to prevent survey citations related to revised CoPs

• Homecare Direction, Issue 8, August 14, 2017

  Create a checklist to verify that your agency has explained to patients and/or their legal...

We are a hospice. What should our response process be to an ADR?

• Homecare Q&A, Issue 15, August 3, 2017

  When a hospice discovers a new ADR, staff should review the time frame for the ADR, assemble...

What constitutes medical necessity when it comes to psychiatric care?

• Homecare Q&A, Issue 15, August 3, 2017

  The proof of medical necessity strictly relies on the MD documentation and diagnosis and the...

How can we prepare for the pre-claim demo?

• Homecare Q&A, Issue 5, August 3, 2017

  Become more proactive. You no longer can wait for face-to-face documentation to arrive within...

How does the new HHGM payment rule for 2019 affect my therapy services?

• Homecare Q&A, Issue 15, August 3, 2017

  In the new proposed home health PPS rule, CMS states agencies providing a larger percentage of...

Moratoria on enrollment for certain home health agencies extended

• Homecare E-News, Issue 29, July 31, 2017

  According to the Federal Registrar, enrollment of new Medicare home health agencies, subunits, and...

New HHGM for 2019 is major overhaul

• Homecare E-News, Issue 29, July 31, 2017

  The introduction of the Home Health Groupings Model (HHGM) into the proposed rule means preparing...

Agencies' payments will drop in 2018

• Homecare E-News, Issue 29, July 31, 2017

  While the HHGM is the most significant long-term change for agencies’ payments, in the short...

New emergency preparedness guidelines provide clues for what surveyors will focus on

• Homecare Direction, Issue 7, July 21, 2017

  Review emergency preparedness policies and procedures at least annually, and make sure they...

We are looking to decrease our rehospitalization rate but we do have a decent number of patients with multiple chronic conditions. What can we do? Can telehealth help? Some of our patients are so frail.

• Homecare Q&A, Issue 14, July 17, 2017

  It’s true that you will struggle. A study of hospitalizations using a national all-payer...

When can we expect to see interpretive guidelines? What should our agency be doing given the new CoP delay?

• Homecare Q&A, Issue 14, July 17, 2017

  The clock has been reset, and agencies that haven’t taken steps to prepare for the revised...

Changes to make with new Medicare cards

• Homecare E-News, Issue 27, July 17, 2017

  The Medicare Access and CHIP Reauthorization Act of 2015 requires CMS to remove social security...

OSHA electronic reporting raises concerns for healthcare providers

• Homecare E-News, Issue 27, July 17, 2017

  Less than one week before the July 1 compliance date, OSHA officials delayed a new electronic...

CMS finalizes home health CoP delay days before effective date

• Homecare E-News, Issue 26, July 10, 2017

  Less than a week before most of the revised Home Health Conditions of Participation (CoPs) were...

Implement a strong performance improvement project as part of QAPI

• Homecare Direction, Issue 7, July 10, 2017

  Your agency has gone through the quality assessment piece of QAPI and identified areas that need...

Final Home Health CoPs: Minimize the cost of compliance

• Beacon Institute On-Demand Webcast Library, Issue 2, February 22, 2017

  Final Home Health CoPs: Minimize the cost of compliance

Federal judge issues nationwide preliminary injunction to overtime exemption rule

• Homecare E-News, Issue 45, November 28, 2016

  Last week, a federal judge with the U.S. District Court for the Eastern District of Texas issued a...

IMPACT Act comments due on new measure for home health

• Homecare E-News, Issue 44, November 21, 2016

  The call for public comment on the IMPACT Act of 2014’s cross-setting quality measure on...

In Focus: Authors of study suggest framework for optimizing home health value

• Homecare E-News, Issue 40, October 24, 2016

  The final report from the Alliance for Home Health Quality and Innovation (AHHQI)’s Future...

Weekly Roundup

• Homecare E-News, Issue 40, October 24, 2016

  New communication ruling for home health and hospices takes effect. This week, the Centers...

Is skilled nursing administering allergy injections sub-q twice a week or weekly to a patient (due to no willing or available caregiver) a covered skill under CMS guidelines?

• Homecare Q&A, Issue 18, September 17, 2016

  Medicare will pay for administration of these injections with the proper circumstances and with...

Question on physician interactions and medication reconciliation...

• Homecare Q&A, Issue 17, September 3, 2016

  Remember, as an agency, you must follow the strictest of the guidelines, including your agency...

Our questions are in regards to providing home health aide services to a patient in an assisted living facility (ALF).

• Homecare Q&A, Issue 16, August 22, 2016

  Our questions are in regards to providing home health aide services to a patient in an assisted...

If a clinician has a missed visit, does the primary physician need to be notified within a certain period of time (e.g., two days, two weeks, etc.), or can we add dates of missed visit(s) and reason to the discharge summary?

• Homecare Q&A, Issue 16, August 22, 2016

  The regulation requires the HHA to alert the physician to any changes that suggest a need to alter...

I wanted to verify if the discharge reason in these cases would still be "Transferred to Inpatient Facility" (to match the transfer OASIS)? Or would we enter "Pt Expired" (even though the patient expired at the hospital, not at home)?

• Homecare Q&A, Issue 16, August 22, 2016

  Follow-up question to the one above: Because the patient would not be coming back to us for...

When we enter our discharge reason for home health, is it that the patient was transferred to an inpatient facility, or is the discharge reason that the patient expired?

• Homecare Q&A, Issue 16, August 22, 2016

  When our patients are admitted to an inpatient facility and we complete a transfer OASIS, we...

Weekly Roundup

• Homecare E-News, Issue 28, July 25, 2016

  In this week's roundup: New HHA PEPPER is now available. A new release of the Program...

I want to make sure I am in compliance regarding teaching and training activities. How do you properly document teaching?

• Homecare Q&A, Issue 14, July 17, 2016

  Teaching and training plays a significant role in homecare and is addressed in the Medicare Benefit...

Weekly Roundup

• Homecare E-News, Issue 26, July 11, 2016

  In this week's roundup: False claims penalties to double. Penalties for fraud by healthcare...

How should a physician recertify a patient with endless or ongoing care needs?

• Homecare Q&A, Issue 13, July 3, 2016

  For recertification of a Foley patient or long-term medication management, the physician should...

In Focus | Supreme Court Refuses Minimum Wage Case

• Homecare E-News, Issue 25, June 27, 2016

  The U.S. Supreme Court has declined to hear Home Care Association of America v. Weil, which means...

Weekly Roundup

• Homecare E-News, Issue 25, June 27, 2016

  In this week's roundup: CMS revises ICD-10 codes. CMS officially finalized the first major...

Weekly Roundup

• Homecare E-News, Issue 24, June 20, 2016

  In this week's roundup: Study: Home health cuts costs of CJR. The use of home health...

Weekly Roundup

• Homecare E-News, Issue 22, June 6, 2016

  In this week's roundup: House members slam home health prior authorization proposal.  A...

Can a discharge planner pull information from a patient's record and document the clinical findings for the need for each discipline and homebound clinical findings?

• Homecare Q&A, Issue 10, May 17, 2016

  As a representative of the physician, the discharge planner could gather all information. As long...

What experience and training do you need to require of an aide for hire?

• Homecare Q&A, Issue 8, April 19, 2016

  As a Medicare-certified homecare agency, I historically hired aides that have completed the CNA/HHA...

What is the best way to comply with the new Medicare regulation that took effect on August 11, 2015, which is the recertification attestation by MDs?

• Homecare Q&A, Issue 8, April 17, 2016

  What is the best way to comply with the new Medicare regulation that took effect on August 11...

What is the best approach to a summary report?

• Homecare Q&A, Issue 7, April 4, 2016

  The Conditions of Participation (CoP) mandate the agency to send a summary report to the physician...

When should we conduct chart audits?

• Homecare Q&A, Issue 7, April 4, 2016

  You can never conduct too many chart audits. However, there are certain time points when you...

What should you do about a tardy recertification assessment?

• Homecare Q&A, Issue 7, April 4, 2016

  In response to this question, CMS has said that it is not necessary to discharge and readmit the...

Under the Medicare home health benefit, does an individual who qualifies for the skilled service of insulin administration due to his blindness and no willing or able caregiver need to be homebound?

• Homecare Q&A, Issue 7, April 4, 2016

  One of the eligibility criteria for Medicare is homebound status; this must be present to qualify...

Weekly Roundup

• Homecare E-News, Issue 14, April 4, 2016

  Recent investigations by the Office of Inspector General (OIG) have shown a number of instances in...

Weekly Roundup

• Homecare E-News, Issue 13, March 28, 2016

  The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) has launched...

Weekly Roundup

• Homecare E-News, Issue 12, March 21, 2016

  The CMS Office of Minority Health last week unveiled a snapshot of chronic disease-related service...

If a patient is blind or in a wheelchair, does he or she automatically meet the requirement for homebound status?

• Homecare Q&A, Issue 6, March 18, 2016

  If a patient is blind or in a wheelchair, does he or she automatically meet the requirement for...

Please advise regarding how a home health agency is paid if a patient elects hospice after admission. At one time, the agency was paid for an entire episode. Is this still the case? What if less than five visits were conducted?

• Homecare Q&A, Issue 6, March 18, 2016

  Please advise regarding how a home health agency is paid if a patient elects hospice after...

Following up on the previous question's example of the therapy overpayment, would the agency also be obligated to look at all the claims for that individual for the prior six years? What do you recommend regarding pre-bill audits?

• Homecare Q&A, Issue 6, March 18, 2016

  Following up on the previous question's example of the therapy overpayment, would the agency also...

What potential impact does the final rule on overpayments have on home health agencies?

• Homecare Q&A, Issue 6, March 18, 2016

  What potential impact does the final rule on overpayments have on home health agencies? For...

Question on physician signatures

• Homecare Q&A, Issue 6, March 18, 2016

  We have been getting complaints from physicians regarding too much paperwork that we send to them...

Weekly Roundup

• Homecare E-News, Issue 11, March 14, 2016

  An article titled “A Case Exemplar for National Policy Leadership: Expanding Program of...

How should we handle our annual agency evaluation? What exactly is this and what does it entail?

• Homecare Q&A, Issue 5, March 3, 2016

  The policies and administrative practices of the agency are reviewed to determine the extent to...

How do I help my staff avoid professional negligence claims? What are the important points to convey to them?

• Homecare Q&A, Issue 4, February 18, 2016

  How do I help my staff avoid professional negligence claims? What are the important points to...

What do the CoPs say about Lovenox administration?

• Homecare Q&A, Issue 4, February 18, 2016

  I work at a homecare agency, and we have been getting referrals lately for nurses to administer...

Weekly roundup

• Homecare E-News, Issue 7, February 15, 2016

  CMS intends to start a Medicare Probable Fraud Measurement Pilot for home healthcare services...

Can the OASIS then be updated (by the assessing clinician) within the five-day window, using information gathered from that collaboration, if the M0090 date is also updated?

• Homecare Q&A, Issue 3, February 3, 2016

  Thank you for your question and commitment to compliance. You are correct that the assessment must...

May we accept orders for labs from a physician assistant (PA) who is listed on the 485?

• Homecare Q&A, Issue 3, February 3, 2016

  Thank you for your question and your commitment to compliance. According to the Medicare Benefit...

What are the legal risks with telehealth?

• Homecare Q&A, Issue 1, January 3, 2016

  Telehealth devices are becoming more common in the area of home healthcare. It is important for...

Are clerical staff able to enter written orders from the MD into the electronic medical record if the RN verifies the entry in both Michigan and Wisconsin?

• Homecare Q&A, Issue 24, December 17, 2015

  It is not prohibited but will require tight controls in place. Please review practice brief about...

Do we need to do a Transfer and Resumption of Care for a patient that was in the hospital for observation longer than 24 hours but not as an inpatient?

• Homecare Q&A, Issue 24, December 17, 2015

  The following is a clarification by CMS regarding this subject:

Weekly Roundup

• Homecare E-News, Issue 49, December 14, 2015

  The Centers for Medicare & Medicaid Services (CMS) will host an open door forum on Thursday...

Weekly Roundup

• Homecare E-News, Issue 48, December 7, 2015

  The National Quality Forum (NQF) announced its plan to review standardized performance measure...

Barring any state restrictions, are home health aides employed by a Medicare--certified agency permitted to apply a dry dressing to a wound if a patient prepares it or not?

• Homecare Q&A, Issue 23, December 4, 2015

  No, home health aides are not permitted to apply any dressing to a wound, incision, etc.  They...

In Focus | Improper payments remain an issue

• Homecare E-News, Issue 47, November 30, 2015

  The U.S. Department of Health and Human Services released its Agency Financial Report for fiscal...

Weekly Roundup

• Homecare E-News, Issue 47, November 30, 2015

  Assisted- and independent-living centers can be attractive places to do business for the home...

How can we prepare for staff interviews during a survey?

• Homecare Q&A, Issue 22, November 17, 2015

  How can we prepare for staff interviews during a survey?

How do home visits work when you are having a survey?

• Homecare Q&A, Issue 22, November 17, 2015

  How do home visits work when you are having a survey?  

Do we need documentation regarding the legitmacy of a discharge planner?

• Homecare Q&A, Issue 22, November 17, 2015

  Our agency is asking for clarification of whether an agency relationship exists between hospital...

In Focus | 2016 Home Health Final Rule Released

• Homecare E-News, Issue 43, November 2, 2015

  After receiving 118 comments from the public during the official comment period, the Centers for...

The Weekly Roundup

• Homecare E-News, Issue 43, November 2, 2015

  Final Rule Released After receiving 118 comments from the public, the Centers for Medicare &...

Inside Story | Determining and documenting the appropriate visit frequency

• Homecare E-News, Issue 42, October 26, 2015

   For years there has been debate on what is an appropriate frequency for a patient. Frequency...

In focus | Study finds home health readmission rates decline, but home health use differs by location

• Homecare E-News, Issue 42, October 26, 2015

   The Alliance for Home Health Quality and Innovation (AHHQI), a national non-profit consortium...

The Weekly Roundup

• Homecare E-News, Issue 42, October 26, 2015

   Home health sees decline in readmission rates The Alliance for Home Health Quality and...

The Inside Story | Staff education on infection control

• Homecare E-News, Issue 40, October 19, 2015

  Care delivered according to infection control guidelines is the most effective tool available for...

In focus | NAHC submits comments on face-to-face clinical templates

• Homecare E-News, Issue 41, October 19, 2015

  Last Tuesday, NAHC submitted official comments to CMS on a pair of proposed clinical templates (one...

We are in disagreement about whether that is an appropriate frequency.

• Homecare Q&A, Issue 20, October 16, 2015

  We are in disagreement about whether that is an appropriate frequency.  

What kind of events count as "potentially avoidable"? What will and should be in the CASPER Outcome-Based Quality Improvement Report?

• Homecare Q&A, Issue 20, October 16, 2015

  What kind of events count as "potentially avoidable"? What will and should be in the...

Can you explain the IMPACT Act and what home health agencies need to do in regard to it?

• Homecare Q&A, Issue 20, October 16, 2015

  Can you explain the IMPACT Act and what home health agencies need to do in regard to it?  

Is it true that the following documentation is an improper certification statement on our home health agency's plan of care?

• Homecare Q&A, Issue 20, October 16, 2015

  Is it true that the following documentation is an improper certification statement on our home...

The Inside Story | Start-of-Care and Resumption-of-Care Assessments

• Homecare E-News, Issue 40, October 12, 2015

  The start-of-care (SOC) assessment is completed as a patient is being admitted to a home health...

In focus | NAHC summarizes latest developments on the face-to-face reform front

• Homecare E-News, Issue 40, October 12, 2015

  While awaiting an imminent decision in its lawsuit challenging the validity of the physician...

If the patient does not require a skilled bath, can our agency continue to provide this under the state personal care program?

• Homecare Q&A, Issue 19, October 2, 2015

  If the patient does not require a skilled bath, can our agency continue to provide this under the...

Can you please explain what specifically needs to be under the supervisions of licensed professionals?

• Homecare Q&A, Issue 19, October 2, 2015

  Can you please explain what specifically needs to be under the supervisions of licensed...

We are having an issue with noncoverage for therapy. What are the rules for therapy services to be covered? Could you explain and expand, providing some examples?

• Homecare Q&A, Issue 19, October 2, 2015

  We are having an issue with noncoverage for therapy. What are the rules for therapy services to be...

We have been told that the following documentation would position us for a potential claim denial. Can you help explain?

• Homecare Q&A, Issue 19, October 2, 2015

  We have been told that the following documentation would position us for a potential claim denial...

We have received a request from a physician office to have one of our employees be on-site to accept and process referrals for home health and hospice.

• Homecare Q&A, Issue 19, October 2, 2015

  We have received a request from a physician office to have one of our employees be on-site to...

How do we update the comprehensive assessment for a major deterioration in status with the PPS payment requirements?

• Homecare Q&A, Issue 18, September 17, 2015

   This patient’s change in condition has a real impact on resource utilization—an...

What should be our frequency of visits?

• Homecare Q&A, Issue 18, September 17, 2015

   We have an 87-year-old woman who was referred by the wound care center for care of a wound...

Do regulations mandate any particular form or format for documentation or confirmation of verbal orders?

• Homecare Q&A, Issue 17, September 8, 2015

  No. The regulations do not mandate any particular form or format for documentation or confirmation...

Is it true that instead of discharging patients when goals are met, we can recertify them under management and evaluation?

• Homecare Q&A, Issue 15, August 3, 2015

  What this agency heard is in error and could lead to denials. Just as with any Medicare-covered...

How are we supposed to use observation and assessment for patients on telemonitoring?

• Homecare Q&A, Issue 15, August 3, 2015

  Telemonitoring or telehealth is one technology that can help a patient in the home. It cannot...

Is it permissible for a hospital discharge planner to make an entry into a patient hospital record and have the physician sign the entry (to support home health eligibility)?

• Homecare Q&A, Issue 15, August 3, 2015

  Is it permissible for a hospital discharge planner to make an entry into a patient hospital record...

How to score an incomplete OASIS?

• Homecare Q&A, Issue 15, August 3, 2015

  I am specifically looking for the guidance indicating that, when an OASIS assessment is not...

If there are verbal orders at start of care, do we need to use Locator 23?

• Homecare Q&A, Issue 14, July 16, 2015

  This locator applies only if verbal orders are involved in the start of care process. It...

Is it true that we must receive the signed plan of care and all verbal orders prior to submitting the claim?

• Homecare Q&A, Issue 14, July 16, 2015

  Yes, it’s true. You can find that requirement in CMS Publication 100-2, Chapter...

Can physical therapy go out and have consents signed and perform an evaluation before the nurse gets to the home to complete the OASIS as long as it is all done the same day?

• Homecare Q&A, Issue 14, July 16, 2015

  The only similar guidance found was according to CMS’ OASIS Q&A:

I am wondering how to answer OASIS assessment "M" items when an OASIS assessment is needed for a payer change, but one does not exist.

• Homecare Q&A, Issue 14, July 16, 2015

  Thanks for your question and commitment to compliance. In cases where you learn after the fact...

How do we get paid when we have two different payers?traditional Medicare (Part A) and MA?within the same 60-day episode?

• Homecare Q&A, Issue 13, July 2, 2015

  If a patient switches from traditional Medicare to MA, the agency will receive a partial episode...

What would be the response for M0150, Current Payment Sources, for an MA patient?

• Homecare Q&A, Issue 13, July 2, 2015

  AM0150 would be answered “2”—Medicare (HMO/managed care/Advantage plan). It is...

Do we answer M0063, Medicare Number, with the patient?s now-defunct Medicare number or the new MA policy number?Do we answer M0063, Medicare Number, with the patient?s now-defunct Medicare number or the new MA policy number?

• Homecare Q&A, Issue 13, July 2, 2015

  When a patient joins a Medicare Advantage (MA) plan, he or she takes on a subscriber number, but...

We continue to have confusion over what is considered a ?nonroutine supply.? Can you help clarify?

• Homecare Q&A, Issue 13, July 2, 2015

  The coverage of nonroutine supplies is probably the most confusing component of the consolidated...

Will Medicare cover lymphedema therapy?

• Homecare Q&A, Issue 13, July 2, 2015

  Lymphedema therapy is an extensive treatment involving a combination of manual decongestive therapy...

Can physical therapy be considered the qualifying service to establish a need for ongoing occupational therapy?

• Homecare Q&A, Issue 13, July 2, 2015

  Occupational therapy cannot qualify a patient for coverage initially, but after the patient has had...

What can trigger an ABN, and what must be documented? What about an HHCCN?

• Homecare Q&A, Issue 13, July 2, 2015

  The ABN (CMS-R-131) is a written notice that the agency must provide to a PPS Medicare-eligible...

Should there be one signature per order, or can orders be batch signed?

• Homecare Q&A, Issue 13, July 2, 2015

  As long as the order is a complete order for a treatment or therapy, you may have more than one...

Homecare Q&A

• Homecare Q&A, Issue 13, July 2, 2015

  July 3, 2015

If an agency discharges a patient with goals met but then readmits him or her within 60 days of discharge, would the new episode be an early or later one for M0110, episode timing?

• Homecare Q&A, Issue 12, June 15, 2015

  If an agency discharges a patient with goals met but then readmits him or her within 60 days of...

How do we determine diagnosis and priority?

• Homecare Q&A, Issue 12, June 15, 2015

  Q: We are seeing a patient with Alzheimer’s disease, who was hospitalized for advanced...

What about goals, rehabilitation potential, and discharge plans? What are some key points we need to keep in mind while entering those into the 485?

• Homecare Q&A, Issue 12, June 15, 2015

  What about goals, rehabilitation potential, and discharge plans? What are some key points we need...

What is the proper way to enter in orders for disciplines and treatments on the 485?

• Homecare Q&A, Issue 12, June 15, 2015

  What is the proper way to enter in orders for disciplines and treatments on the 485?

Where can I find that it would be illegal to charge a Medicare home health patient prior to rendering services, while reimbursing patient once CMS has paid the claim?

• Homecare Q&A, Issue 12, June 15, 2015

  Assignment of benefits - This term means that the facility or the physician agrees to accept...

What does Patient Care 484.60: Care Planning, Coordination of Services and Quality of Care mean for agencies?

• Homecare Q&A, Issue 8, June 9, 2015

   First, let’s review for everyone reading what the current CoP is and what is being...

When there is a patient who might be a candidate for maintenance therapy, how do we conduct a proper assessment to determine what kind of therapy is needed?

• Homecare Q&A, Issue 0, June 9, 2015

  Although the diagnosis and the functional limitations do not stand alone in determining the medical...

Can we use standing orders for many of our specialty programs, like wound care?

• Homecare Q&A, Issue 11, June 3, 2015

  Can we use standing orders for many of our specialty programs, like wound care?

Can we accept orders from a physician?s secretary or office nurse who is communicating with us instead of the physician?

• Homecare Q&A, Issue 11, June 3, 2015

  Can we accept orders from a physician’s secretary or office nurse who is communicating with...

What do we do if a patient has been snatched away from us?

• Homecare Q&A, Issue 11, June 3, 2015

  What do we do if a patient has been snatched away from us?

Can a nurse practitioner who runs her own practice make a referral to a home health agency?

• Homecare Q&A, Issue 11, June 3, 2015

  Can a nurse practitioner who runs her own practice make a referral to a home health agency?

How are we supposed to use observation and assessment for patients on telemonitoring?

• Homecare Q&A, Issue 10, May 17, 2015

  How are we supposed to use observation and assessment for patients on telemonitoring?

How can extended daily visits be justified and covered?

• Homecare Q&A, Issue 10, May 17, 2015

  How can extended daily visits be justified and covered?

Where can I find the rule about physician cosigning of a nurse practitioner's order so the order is valid?

• Homecare Q&A, Issue 10, May 17, 2015

  Where can I find the rule about physician cosigning of a nurse practitioner’s order so the...

Where is it specifically written that an NP or a PA cannot sign homecare orders?

• Homecare Q&A, Issue 10, May 17, 2015

  Where is it specifically written that an NP or a PA cannot sign homecare orders?

Can we use "zero" as a frequency in writing physician orders?

• Homecare Q&A, Issue 10, May 17, 2015

  Can we use “zero” as a frequency in writing physician orders? For example, physical...

Can a single physical therapy visit determine a need for occupational therapy that is covered under Medicare?

• Homecare Q&A, Issue 10, May 17, 2015

  Can a single physical therapy visit determine a need for occupational therapy that is covered under...

What are the new therapy reassessment requirements that CMS solidified in its 2015 PPS final rule?

• Homecare Q&A, Issue 10, May 17, 2015

  What are the new therapy reassessment requirements that CMS solidified in its 2015 PPS final rule...

If a RN sees a patient on Monday, April 13, 2015, when is the next supervision visit due?

• Homecare Q&A, Issue 10, May 15, 2015

  If a RN sees a patient on Monday, April 13, 2015, when is the next supervision visit due? I...

What does the proposed standard Patient Care 485.65: Quality Assessment & Performance Improvement mean for my agency?

• Homecare Q&A, Issue 9, May 3, 2015

  My agency has been reviewing the proposed Conditions of Participation (CoP). We are looking at the...

What should you do about a tardy recertification assessment?

• Homecare Q&A, Issue 9, May 3, 2015

  What should you do about a tardy recertification assessment? It’s the fifth day of the...

What happens to patients who can self-inject but cannot pre-fill insulin syringes?

• Homecare Q&A, Issue 9, May 3, 2015

  What happens to patients who can self-inject but cannot pre-fill insulin syringes?

When does Medicare consider a wound as chronic/nonhealing and no longer pay for services?

• Homecare Q&A, Issue 9, May 3, 2015

  When does Medicare consider a wound as chronic/nonhealing and no longer pay for services?

Is it an appropriate use of Medicare to do three weeks of assessment and venipuncture for a patient hospitalized with deep vein thrombosis (DVT)?

• Homecare Q&A, Issue 9, May 3, 2015

  Is it an appropriate use of Medicare to do three weeks of assessment and venipuncture for a patient...

Do we answer M0063, Medicare Number, with the patient?s now-defunct Medicare number or the new Medicare Advantage (MA) policy number?

• Homecare Q&A, Issue 8, April 17, 2015

  When a patient joins an MA plan, he or she takes on a subscriber number, but the patient’s...

When are you to begin counting the 30 days from assessment to assessment?

• Homecare Q&A, Issue 8, April 17, 2015

  The final rule, and the corresponding correction that CMS put out regarding the therapy...

When was the final rule issued that therapy goals must be delineated as short- and long-term with explicit completion time frames?

• Homecare Q&A, Issue 8, April 17, 2015

   The 2015 final rule for home health PPS changed the policy on Medicare therapy reassessments.

Can you shed some light on specific circumstances that warrant the resumption of care assessment?

• Homecare Q&A, Issue 7, April 3, 2015

  The ROC assessment is completed any time a patient has returned home following an inpatient stay of...

Where in the CMS guidelines does it indicate that there should be short-term and longterm goals for therapy?

• Homecare Q&A, Issue 7, April 3, 2015

  Palmetto and CGS have specific local coverage determinations (LCD) regarding shortand long-term...

How can we ensure we?re meeting and documenting eligibility requirements effectively?

• Homecare Q&A, Issue 7, April 3, 2015

  Before offering the Medicare Hospice Benefit (MHB) to a beneficiary, the hospice must first verify...

Is it true that we need to change our process and submit ALL OASIS assessments to the AS

• Homecare Q&A, Issue 6, March 17, 2015

   Yes, all Medicare, Medicare Advantage, and Medicaid OASIS assessments must be transmitted.

How can I ensure more effective meetings at our agency?

• Homecare Q&A, Issue 5, March 3, 2015

  We spend a tremendous amount of time in meetings. Many of them are boring, nonproductive, and...

Is it true that the physical therapist has to make a visit no less than once every two weeks when a physical therapy assistant is involved with the same case and primarily doing most visits?

• Homecare Q&A, Issue 5, March 3, 2015

  On the federal level, the CoPs/ Medicare Benefit Policy Manual states that for all certified...

Is there a requirement to have our annual program review/PAC minutes approved by our board of directors each year?

• Homecare Q&A, Issue 5, March 3, 2015

  There is not a specific Condition of Participation (CoP) stating that the board must review your...

Will home health remain exempt from overtime compensation in most circumstances like it has for 40 years?

• Homecare Insider, Issue 1, January 5, 2015

  Will home health remain exempt from overtime compensation in most circumstances like it has for 40...

January 3, 2013

• Homecare Q&A, Issue 1, January 3, 2013

   Access the January 3, 2013 issue of Homecare Q&A.