Home Health & Hospice

A Little-known Repercussion for Not Following the Rules

Homecare Insider, January 19, 2009

Homecare providers are very familiar with payment denials, the repercussions that follow noncompliance with Medicare coverage criteria.  There are also survey citations, those repercussions for not abiding by the Conditions of Participation.  There can also be a payment penalty for not complying with a certification requirement.  

Can we bill for home health aide visits if supervision was not done every two weeks as required?

You may wonder why someone asked this question.  Supervision is a certification requirement (in the Conditions of Participation) and billing for visits deals with coverage and payment criteria.  Surveyors focus on the certification requirements and intermediaries on the other two.

However, that may be changing.  Some agencies have incurred denial of aide services because of improper supervision.  The Code of Federal Regulations spells out the criteria an agency must follow in order to receive Medicare payment.  One of those:  The agency must comply with the requirements set forth in the Conditions of Participation.  If an agency does not supervise the aide according the regulations, then it has not complied with the payment requirements.

Denial of aide services because of noncompliant supervision does not appear to be widespread... yet.  However, it can be a basis for a denial.  If an agency knows that aide services were not supervised properly and it submitted a bill for them anyway, might an intermediary accuse this agency of fraud (that is, knowingly billing for noncovered services)?  Take the actions necessary to avoid these repercussions.  Teach clinicians about the requirements for home health aide supervision and monitor compliance.

Don’t forget about the requirement for every home health aide to receive 12 hours of in-service education every 12-month period.  Check out Beacon Health’s seven volumes of Home Health Aide On-the-go™ in-service lessons.  You’ll find a lesson to meet any educational need.