Home Health & Hospice Week

CMS issues new guidelines on the controversial practice.

If you let your drop sites cross the line into branch territory, the mistake could be fatal for your home health agency.
 
The Centers for Medicare & Medicaid Services has issued new guidelines on the practice of HHAs using "drop sites, workstations, way stations, convenience sites, or satellites," according to a Nov. 12 memo to surveyors (S&C-05-07).
 
The bottom line: As long as state and local laws permit drop sites, CMS has no problem with them, the agency says in the memo.
 
Caveat: But agencies must be very careful to make sure the drop sites don't wander into unauthorized branch territory. "HHAs that allow these locations to cross the line from drop site to branch are out of compliance with the Medicare requirements," CMS warns.
 
"It was nice for CMS to clarify this," notes consultant Judy Adams with the Charlotte, NC-based LarsonAllen Health Care Group. Agencies have been confused about the issue ever since CMS said in an Open Door Forum this summer that it didn't authorize drop sites (see Eli's HCW, Vol. XIII, No. 23, p. 180). Earlier this year, a Colorado HHA saw its Medicare termination upheld based on an unauthorized branch that it contended was a "paperwork drop box."
 
Drop sites are very convenient for agencies that cover a geographically large service area, notes consultant Pat Sevast with American Express Tax & Business Services in Timonium, MD. They allow staff to save time and mileage by avoiding extra trips to the main office, Sevast notes.
 
Drop site no-no's: Assigning staff to drop sites, accepting referrals at the locations, advertising them as a part of the HHA, or operating them "in any other way as branches of the HHA" are strictly off limits, CMS makes clear in the memo.
 
Basically, your drop sites should "remain simple locations with a phone, forms, computers, etc.," advises Chicago-based consultant Rebecca Friedman Zuber, a former Illinois survey official. "Don't 'cover' a portion of your service area from this location."
 
That means no secretaries, no supervisors, no meetings, no sign advertising the agency, no published phone number and no medical records maintained there, Sevast stresses. "It shouldn't look like you're operating an agency out of there," she tells Eli.
 
Visiting staff should see the drop site as a place to use a clean restroom and have lunch, Adams quips. They can complete documentation and communicate with other HHA staff, she notes. And staff can pick up supplies there, Sevast adds.

Records, Phone Calls are Gray Areas

How an agency handles medical records is one of the most important parts of keeping a drop site from operating as a branch, experts say. If you appear to be keeping records in any way at the site, surveyors could consider it an unauthorized branch, Adams warns.
 
Agencies that want to play it completely safe shouldn't allow staffers to leave records at a drop site at any time, Adams says. Some agencies may get into trouble by allowing staff to leave records at the drop site that don't get picked up for a week or more, she worries. That starts to look like the agency is storing records at the site, she cautions.
 
Most surveyors probably won't have a problem with records being picked up at a location more frequently, Sevast expects.
 
Another gray area is phone calls and faxes, Adams cautions. HHAs can't take referrals at the locations or advertise them as part of the HHA, the CMS memo specifies. That means agencies should keep the number unlisted, she advises.
 
But problems still may crop up if staff call or fax referral sources or patients from the site. With caller ID prevalent, physicians and patients may just call the number that shows up on their ID rather than the number the agency gives them, Adams points out. In one scary scenario, a physician may fax an order change to the site fax number, and the new orders don't get picked up for days.
 
Smart agencies will use phones and faxes at drop sites only for internal communication, Adams says. "You don't want the community to perceive [the site] number as the phone number to use," she notes. 
 
Editor's Note: The memo is at www.cms.hhs.gov/medicaid/survey-cert/sc0507.pdf.