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.