Medicare Compliance & Reimbursement

The Centers for Medicare & Medicaid Services has thrown home health agencies one bone in its recent memo on comprehensive assessments (see story, "Oasis Suspensions Add More Work For HHAs").
 
HHAs don't have to wait until days 55-60 to perform comprehensive assessments on non-Medicare, non-Medicaid patients unless they want to, CMS spells out in S&C-04-26. "The assessment may be performed any time up to and including the 60th day," CMS says.

"For example, if a non-Medicare/non-Medicaid patient's payer source requires a revised plan of care on day 50 of the episode, the clinician could conduct the follow-up assessment earlier than day 50 without conducting a second assessment on day 55-60," CMS explains.

The timetable for the next 60-day period would start whenever the last assessment is conducted, the memo specifies.

This is good news, since generally "non-Medicare/Medicaid clients are not reimbursed in episodes but by visit," notes Linda Rutman, consultant with Charlotte, NC-based LarsonAllen Health Group. Those patients "often do not have to be seen during the final five days of a 60-day period," Rutman points out.

Now private pay patients who require recertification will "no longer be held to the episodic mandate for the recertification comprehensive assessment," Rutman cheers.