Home Health & Hospice Week

Survey & Certification:

Be Ready To Jump On Subunit Conversion Instructions

Converted subunit surveys to get bumped up.

Home health agencies hoping Medicare would give them extra time to comply with the new CoPs' requirement to convert subunits to either freestanding agencies or branches have had their hopes dashed.

In the Nov. 15 Home Health Open Door Forum, a Centers for Medicare & Medicaid Services official explained that instructions for converting subunits would be out by the end of the week, and agencies would have to comply by the January implementation deadline.

Big change: HHAs who want to convert subunits to freestanding agencies will have to appoint a new separate administrator and governing body for the converted agency, the CMS representative explained. Agencies will not be able to share administrators or governing bodies, the CMS source confirmed in the question-and-answer portion of the forum.

If you fail to notify your state survey agency or your HHH Medicare Administrative Contractor of your preference in converting your subunit, the surveyors and MAC will assume you are converting the subunit to a freestanding agency, the official said.

Surveyors won't rush out and survey every converted subunit immediately in January to see whether they are meeting freestanding agency requirements, the rep said. But they will "move up" surveys of subunits in hopes of having all those types of surveys completed in the next year or so, she told forum attendees.

Remember:With alternative sanctions such as payment suspensions and civil money penalties now available to surveyors, even somewhat minor survey infractions can cost you dearly.

Stay tuned: Instructions for filing the paperwork for your subunit conversion will be in the memo expected by Nov. 17, CMS said.

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