Home Health & Hospice Week

If you don't live up to your correction plan, your Medicare number could be forfeit. If you have any doubts about how long survey appeals can take, look at the case of Boulder, CO-based Professional Home Health Care Inc.

An administrative law judge with the HHS Departmental Appeals Board issued a decision in January 2004 for a survey determination made in May 2001. And the DAB decision wasn't favorable to the home health agency with branches in Denver, Longmont and Greeley.

A March 2001 surveyor found PHHC out of compliance with two conditions of participation and hit the agency with 10 standard-level deficiencies, according to PHHC Inc. v. CMS (Docket No. C-01-752, Decision No. CR1128). And a May 2001 resurvey found the HHA hadn't lived up to its plan of correction.

Surveyors cited a range of problems from late physician orders to not picking up lab results to running an unauthorized branch office. PHHC "was not complying with two conditions of participation," the decision says. "Moreover, I have found that Petitioner's deficiencies could limit its ability to furnish adequate care or adversely affect patient health and safety. Thus, [the Centers for Medicare & Medicaid Services] was authorized to terminate Petitioner's participation in Medicare as a home health agency."

Watch out for rehab facility components coming to a critical access hospital near you. When filling out M0175, HHAs may want to keep in mind that CAHs now will be allowed to set aside units of up to 10 beds each to be used for inpatient rehabilitation and psychiatric services. Restricting the services covered under Medicare's home health benefit is one idea for limiting the growth of Medicare and Medicaid long-term care spending, the Congressional Budget Office says in an April report, "Financing Long-Term Care for the Elderly."

"The adjustments ... could be phased in over an extended period to allow people time to appropriately adjust their long-range financial plans," CBO suggests. Home health quality measures are under consideration by a National Quality Forum home health panel, CMS says. The NQF's Home Health Steering Committee will meet throughout the fall and summer. Information on the project, which aims to endorse a set of measures for gauging home health quality, is at www.qualityforum.org/txhomehealthNQFprojsummaryFINAL+SCroster.pdf. HHAs don't have to bend over backwards to meet the Joint Commission on Accreditation of Healthcare Organization's National Patient Safety Goal #1. The goal, on accurate identification of care recipients, "is much easier and less prone to error" in the home than in other settings, JCAHO says in its latest Home Care Bulletin.

At a first encounter, the HHA should require two identifiers, the Joint Commission instructs. There-after, one of the identifiers can be facial recognition if the clinician knows the patient. The [...]