Home Health & Hospice Week

Changing to a freestanding agency is the default.

There are two paths to changing your subunit to comply with the new Home Health Conditions of Participation that take effect Jan. 13.

In a Nov. 17 Survey & Certification Memo, the Centers for Medicare & Medicaid Services says that the HHH Medicare Administrative Contractors "have already established separate enrolment records for the currently existing Subunits." It's up to home health agencies to do the rest.

Converting To A Freestanding Agency

In memo S&C: 19-03-HHA, CMS lays out these steps HHAs must take when changing their subunits into freestanding agencies:

• Submit a revised CMS-855A to the MAC changing its Provider Type (Section 2) from Home Health Agency (Subunit) to Home Health Agency. "This is considered a Change of Information and no further action is required by the former Subunit," CMS explains.
• "Since the former Subunit now has a separate enrollment record, the Parent does not need to make any changes to their CMS-855A regarding the transition of the Subunit to a distinct/freestanding HHA," CMS adds.
• Submit a revised Form CMS-1572a, with fields 1-15B and 16-20 completed by the former Subunit. "The field on the form, Type of Survey, should be denoted and the form entered into ASPEN as 'initial (1),'" CMS instructs. "At the time of the next standard survey, the updated Form CMS-1572a should be entered into ASPEN with the Type of Survey denoted as 'Resurvey (1).' The SA will revise the associated Parent's current Form CMS- 1572a to change field 15B to 'no' and enter the change into ASPEN as a 'Resurvey (1).'"
• The SA communicates the transition of the former Subunit to a distinct/freestanding HHA with the CMS Regional Office via Form CMS-1539.
• The new distinct/freestanding HHA retains its CCN and its provider agreement.

Tip: If you don't contact your Survey Agency about converting your subunit, CMS will assume you're converting it to a freestanding agency and the SA will request you submit the CMS-1572a.

Converting To A Branch

The memo sets out these instructions for converting a subunit to a branch:

• Submit a revised Form CMS-1572a to denote the addition of the Branch(es), completing Field 15D. Field 12 of the form should be denoted as "Resurvey (1)." The Parent must also submit evidence of its ability to provide supervision of the new Branch(es). The SA will review each request to ensure that supervision can be provided to the new Branch(es) by the Parent.
• While the SA will review submitted evidence, no survey activity is required until the next scheduled survey of the Parent.
• If the former Subunit operated a Branch(es), these locations may also be transferred to the Parent as Branch(es) pending compliance with the supervision requirements.
• Once the Branch approval is completed, the SA communicates, via Form CMS-1539, its recommendation to the RO for approval of the transition of the former Subunit and its Branch(es) (if applicable) to the Parent.
• If the CMS RO agrees with the SA recommendation to approve the Branch(es), the former Subunit CCN is terminated. ACCN derived from the Parent CCN will be issued to the new Branch(es). "No provider agreement is issued to the new Branch(es) as they will be certified and operate under the Parent's provider agreement," CMS adds.
• The former Subunit must submit a revised Form CMS-855A to its MAC terminating its separate enrollment as a distinct/freestanding HHA. Simultaneously, the Parent must submit a revised Form CMS-855A to the MAC adding the former Subunit and its Branches (if applicable) as a Branch(es) on its enrollment record.
• The CMS RO will forward a Form CMS-2007 to the MAC communicating approval of the addition of all Branch(es) for the Parent. In the Remarks section of the Form CMS-2007, the CMS RO should enter, "Former HHA Subunit transitioned to Branch(es) pursuant to CMS 3819- F. CCN has been terminated."

One Other Option

The subunit also may opt to voluntarily terminate, CMS adds.

Note: More operational details are in the memo at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-18-03.pdf.