Home Health & Hospice Week

Warning: Don’t confuse initial assessment with start of care.

Home health agencies need more relief from Medicare, but regulatory lightening is off to a good start with a raft of new measures.

“The outcome is a mixed bag,” the National Association for Home Care & Hospice says of the interim final rule with regulatory relief issued March 30.“There is still a lot of work to do to break down the barriers to efficient and effective care.”

In addition to broader telehealth, cost report filing extensions, accelerated payments, and a homebound liberalization, the interim final rule includes these measures:

• Initial Assessments. The Centers for Medi-care & Medicaid Services is waiving requirements to allow HHAs to perform Medicare-covered initial assessments and determine patients’ home- bound status remotely or by record review, the agency says in a fact sheet for the interim final rule.

“This is huge for home health,” says Sharon Litwin with 5 Star Consultants in Camdenton, Missouri.“It means that an in-person visit is not required to complete the initial assessment.”

Don’t confuse it: Often, the clinician com-pletes the initial assessment during the same visit in which the Start of Care comprehensive assessment is completed, Litwin notes.But they aren’t the same thing.The initial assessment determines “the immediate care and support needs of the patient and … eligibility including homebound status,” she explains.

“The immediate care and support needs are the items and services that will maintain the patient’s health and safety until the HHA can complete the SOC Comprehensive assessment and establish a plan of care,” Litwin clarifies.“Eligibility including homebound status is also determined at this time.”

Now agencies can perform this via phone call, or even by review of the medical records an agency receives as part of the referral, CMS makes clear in the interim final rule.

Stick to the deadline: “The CMS waiver did not make changes to the timeframe for the initial assessment to be completed,” the rule says.“Whether done remotely, through record review, or in person the initial assessment must still be completed within 48 hours of referral, or within 48 hours of the patient’s return home, or on the physician-ordered SOC date.”

Keep it straight for billing: Stay crystal clear that the “initial assessment” is not the start of care, emphasizes reimbursement expert M. Aaron Little with BKD.“There is no relief at this time from the start of care being in-person,” Little tells Eli.“If the initial assessment is conducted remotely, that it is not a billable visit and the start of care visit will not be until the in-person visit.If agencies misunderstand this distinction, it will cause problems when it comes time to bill RAPs/claims,” he warns.

• OASIS. CMS is waiving the 30-day OASIS submission requirement.Accordingly, CMS is extending the five-day completion requirement for the comprehensive assessment to 30 days.

On one hand: Waiving the requirement that each claim have a matching OASIS file would be much more helpful than just extending OASIS filing deadlines.The rule “does not relieve providers from submitting the OASIS before billing the claims,” Little notes.“This is a critical detail to prevent claims from being denied.” On the other hand: HHAs taking advantage of accelerated payments don’t have to worry about claims filing dates and matching OASIS files for a while.And at least “the only OASIS that must be filed before billing is the Start of Care OASIS or Follow-Up/Other Follow-Up (Recert) OASIS, and Resumption of Care if it is to be linked to the next 30-day claim,” points out Melinda Gaboury with Healthcare Provider Solutions in Nashville.“The biggest relief ...is that they don’t have to stress that all OASIS get completed and transmitted timely.”

• Requests for Anticipated Payment. CMS is allowing HHH Medicare Administrative Contractors to extend the auto-cancellation date of RAPs during emergencies.

This may not be a huge financial boon given RAPs’ relatively small payment impact under the Patient-Driven Groupings Model.But it is “helpful in the sense that agencies will not have to worry about having to refile [RAPs] to get the small amounts back and can focus on other things,” Gaboury judges.

• Aide supervision. CMS is waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan.“This may not be physically possible for a period of time,” the CMS fact sheet says.“This waiver is also temporarily suspending the 2-week aide supervision by a registered nurse ...but virtual supervision is encouraged.” 

Note: The fact sheet is at www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf.