Home Health & Hospice

Be Careful About a 'Way Around'

Homecare Insider, March 23, 2009

Homecare list serve discussions frequently tackle questions about the initial assessment visit and OASIS.  Look at this recent exchange.

List serve question:  Physical therapy will be the qualifying service but you know that the registered nurse will make one visit for either removal of staples or for a lab draw.  Is this a therapy-only case so the physical therapist can complete the OASIS or is this a time that the nurse must do the assessment?
List serve answer:  If nursing is ordered on the original plan of care, the nurse must do the OASIS.  A way around this is to have the original plan of care include only the order for therapy and then follow that a short time before the scheduled nursing visits with a mod order for a one-time nursing visit.  That way, the therapist can do the OASIS.

Beacon Health’s response:  This way around could find the agency on its way to survey problems.  The Conditions of Participation §484.55(a) require the registered nurse to make the initial visit and complete the initial assessment with OASIS if the physician has ordered nursing at the start of care.  This holds true even if nursing is not the qualifying service, as it would be in this case because the physician ordered only one visit.

It is true that if the original order includes only physical therapy, the physical therapist could do the initial visit and assessment.  However, if the agency knows about the need for nursing at the start of care, it is not proper procedure to exclude it from the referral orders.  It would most likely be evident from review of the patient circumstances that the need for suture removal or a blood draw existed before the therapist’s visit.  It would also raise questions as to how the agency managed to schedule a nursing visit in advance of receiving an order.  Plus, the agency might end up not complying with another regulation (for example, if the physical therapist fails to get the order from the physician before the scheduled nursing visit).
Any time you read the words “a way around” or some version thereof, be very careful about the message that follows.  In the short-term, you might save some time.  However, circumventing the intent of the regulations could create major headaches for the agency.

In this era of intensive scrutiny, it is very important for the admitting clinician to establish the qualifying service and develop a sound plan.  An audio recording from the Beacon Health “Best Practices for Medicare Admissions” series can help homecare agencies avoid problems.