Home Health & Hospice Week

New codes bound to impact reimbursement.

It’s not just other home health or hospice agencies you need to worry about overlapping with under COVID-19. Thanks to the new COVID-19 Interim Final Rule, hospital outpatient departments can now bill for visits in the home.

When “the patient is receiving services from the hospital clinical staff as a registered outpatient, the patient’s place of residence cannot be considered a home for purposes of HHA services,” the rule explains.“This is because HHAs cannot bill for services furnished in [provider-based departments] of hospitals, and a patient’s home has provider-based status when the patient is a registered hospital outpatient and HOPD services are being furnished.”

The Centers for Medicare & Medicaid Services says it’s on the hospital to make sure overlap doesn’t occur.“Because the home is not a traditional PBD, and because there are interactions with other types of providers or suppliers who may furnish services in the home, but not in the ‘hospital’ ...hospitals should only consider the patient home to be provider-based to the hospital when the patient is registered as a hospital outpatient,” the Interim Final Rule instructs.“When the patient is not receiving outpatient services by the hospital, the patient’s home can be considered a home for purposes of the home health benefit and the HHA can furnish and bill for home health services.”

Further, “the hospital should be aware if the patient is under a home health plan of care, and it must not furnish services to the patient that could be furnished by the HHA while the plan of care is active,” CMS maintains.“To the extent that there is some overlap between the types of services a HHA and a HOPD can provide, and the patient has a current home health plan of care, the hospital should only furnish services that cannot be furnished by the HHA.”

Impact: “A home health agency may not open a patient to services if the HOPD is providing outpatient services in the home,” the National Association for Home Care & Hospice says.“Although this might be helpful for HOPD patients receiving wound care and other recurring outpatient services, it could compete with potential home health admissions,” the trade group cautions.