Home Health & Hospice Week

Comprehensive assessments aren't always required, CMS explains in revised SOM.

You could be making extra work for yourself if you don't know which patients need assessments when.
 
The Centers for Medicare & Medicaid Services spells out to which home health agency patients the Medicare conditions of participation apply in a new transmittal revising the online State Operations Manual.
 
When "the only service requested from an HHA by an individual is a chore or other clearly non-medical service ... we will not consider the individual to be a patient of the HHA in the traditional sense of the term," CMS says in the manual revision. That means COP requirements such as "a comprehensive assessment under 42 CFR 484.55 will not apply," CMS instructs.
 
Not so fast: But CMS warns that if there is "ambiguity as to whether a service is non-medical or medical, we will incline towards the medical interpretation and consider the COPs to apply."
 
CMS considers "personal care to be a medical service and to require a plan of care, etc.," Chicago, IL-based regulatory consultant Rebecca Friedman Zuber says of the transmittal. "They are drawing a distinction between the hands-on stuff and the chore housekeeper stuff."
 
"Ambiguity comes in companion services or even homemaker [services] that may drift towards personal care," warns Bob Wardwell with the Visiting Nurse Associations of America. An ambiguous service could be one that is "a little hands-on, but isn't what we typically think of as personal care - maybe light massage, feeding," Zuber muses.
 
"Aide services where the agency is providing primarily home management services, but may also be doing some personal care" might run agencies into trouble, predicts consultant Judy Adams with Charlotte, NC-based LarsonAllen Health Care Group.

Assessment Doesn't Equal OASIS

The SOM revisions also spell out that agencies can conduct more frequent assessments for personal care services patients. "The assessment may be performed any time up to and including the 60th day from the most recently completed assessment," CMS explains.
 
And while personal care services-only and other non-Medicare/non-Medicaid patients' assessments must be comprehensive in line with the COPs, that doesn't mean they must include OASIS, CMS reminds surveyors. "Surveyors must not investigate whether the HHA included the specific OASIS items in its patient-specific comprehensive assessments of non-Medicare/non-Medicaid patients, nor cite deficiencies based solely on this finding," CMS instructs in the transmittal.
 
CMS "leaves it up to the agency to determine what constitutes a comprehensive assessment," Adams notes. "Many HHAs think the only comprehensive assessment is one that includes OASIS and of course, this is not true." 
 
Note: The transmittal is at www.cms.hhs.gov/manuals/pm_trans/R11SOM.pdf.