Home Health & Hospice Week

Add educating hospital discharge planners to your to-do list.

If you don't pay for bundled services or items furnished by other rehab providers or suppliers, your patients may have to.

In a new memo explaining home health consolidated billing, the Centers for Medicare & Medicaid Services makes clear that patients may be on the financial hook for bundled services. "In certain circumstances where the primary [home health agency] is unaware of services provided during the episode and the beneficiary is properly notified, the beneficiary may be liable for payment for these services," CMS says.

"In order to protect the beneficiary from unexpected liability in these cases, and in order to comply with Medicare Conditions of Participation, it is important that all providers and suppliers serving a home health patient notify the beneficiary of the possibility that they will be responsible for payment," CMS instructs.

Notice overload: But home health patients receive so many notifications now that a notice about bundling is likely to just get lost in the shuffle, notes Abilene, TX-based consultant Bobby Dusek. "The stack of paperwork [at admission] is just unbelievable, and many of these patients don't even know what year it is," Dusek laments.

The transmittal's patient liability provisions may be "misused and misunderstood," worries consultant Tom Boyd with Rohnert Park, CA-based Boyd & Nicholas. "The hospital statement to the patient could read, 'We are providing these services to you that may be covered or paid by the HHA. In the event that the HHA does not pay for them you will be required to do so.'"

A more common, acceptable scenario for patient liability is when the patient chooses a different brand of bundled supplies than the agency furnishes, notes consultant M. Aaron Little with BKD in Springfield, MO. "If the patient insists on using Brand X, even though Brand Y is a suitable brand and the agency has given notice to the patient, the patient would be required to pay for that supply," Little explains.

Educate discharge planners: CMS also tasks hospital discharge planners with explaining home health consolidated billing. "Hospitals ... should counsel beneficiaries being discharged to receive home health services, that his/her 'primary' home health agency ... will provide all home health services," CMS says in the transmittal. "Hospitals play a key role in making beneficiaries, and/or their caregivers, aware of Medicare home health coverage policies to help ensure that those services are provided appropriately."

But because many discharge planners may have an imperfect understanding of home health reimbursement, stepping in to help out is a good idea, Little recommends. "It's in the home health agency's best interest to foster relationships with discharge planners," he says. "Provide them with materials that make it as easy as possible to explain [consolidated [...]