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What should you do about a tardy recertification assessment?

Homecare Q&A, May 17, 2015

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Q: What should you do about a tardy recertification assessment?

A: It’s the fifth day of the recertification episode, and the nurse realizes she did not do the follow-up assessment during the five-day window. Now what? In response to this question, CMS has said that it is not necessary to discharge and readmit the patient. The clinician should visit the patient as soon as possible to complete the recertification assessment. But that’s the only simple thing about this dilemma. Here are some of the issues:

• OASIS data submission: The agency will receive a warning message because the date of the assessment is outside the appropriate time frame. Do not, however, change the dates of the certification period or the start of care in an attempt to prevent this warning.
• RAP submission: Do not submit the RAP for the recertification episode until the agency has OASIS data collected and locked and has made the first billable visit in the recertification episode.
• Billing: Can the agency bill for any visits made in the recertification episode before the assessment was done? If the clinician remembered to renew the plan of care for ongoing services, but forgot the assessment, the agency has authorization for the visits in the recertification episode and can include them on the claim. However, if the clinician forgot to do the assessment, there’s a good chance he or she also forgot about the plan of care. In that case, the agency has no authorization for the visits made before the plan was renewed and cannot include them on the claim. The agency can bill for visits made after receiving proper authorization for the recertification plan.
• Survey repercussions: If tardy assessments occur regularly, the agency can face a standardlevel citation for noncompliance with the Conditions of Participation, §484.55(d), update of the comprehensive assessment.

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