Home Health & Hospice

Who Is Responsible for an ALF Patient's Supplies?

Homecare Insider, June 1, 2009

Homecare agencies have been responsible for supplies under the consolidated billing provision of the Prospective Payment System (PPS) since October 1, 2000.  In spite of the eight years of history, there are still challenges.  Consider this question from a Beacon Institute™ member.
Who should be responsible for supplies for a patient in a senior assisted living facility (ALF)?  We admitted a patient for physical therapy ONLY.  Now we have found out that she has a T-tube (status post-cholecystectomy) and also needs nursing and supplies.  The facility advertises nursing supervision but it does not provide care for anything worse than a Stage I wound.  I don’t believe we should be making nursing visits in a facility and because the case is therapy-only, I don't believe we must provide the supplies.

Before answering this question, there is one we must ask.  How did this agency admit this patient without finding out about her post-operative condition and T-tube?  The start of care comprehensive assessment with OASIS includes questions about a surgical wound.  If the admitting clinician had identified this condition, the agency might have decided not to admit this patient.  However, now that she qualifies for coverage and is a patient, the agency must address her homecare needs.

This director has concerns about providing nursing services to a patient in a facility with nursing supervision.  If this ALF provides 24-hour nursing service rendered or supervised by a registered professional nurse, it would be considered an institution, not a residence, for Medicare purposes.  In that case, a homecare agency cannot provide any services.  However, because the facility does not tend to wounds other than Stage I, it probably doesn’t provide 24-hour nursing care.  Chances are that the nurses on staff monitor blood pressure, administer medications, oversee personal care, and provide nonskilled care and general supervision.  If that’s an accurate description, then this facility can be considered the patient’s residence and the agency can provide homecare services to this patient, which includes therapy, skilled nursing, and nonroutine supplies.


An interactive CD, “Nonroutine Supplies in the Medicare PPS,” clarifies the provision and reporting of nonroutine supplies in the PPS.  Learn more about this educational program – CLICK HERE.