FAQs
Home Health | TJC | CHAP | Pediatrics | Start Ups | DMEHome Health Non-Accredited
- Can an outpatient therapy do therapy visits on a home health patient and the home health provide the skilled nursing and aide services only?
- Our patient went into the hospital and is now hospitalized during the time period the recertification is due. What should we do?
- As a home health agency am I required to do TB skin testing on all my employees?
- Does a home health agency have to have all their employees CPR certified?
- If a home health agency offers home health aide services and these services are provided by a registered nurse, does the agency have to have a registered nurse supervise the registered nurse making the home health aide visits?
- Is a home health agency required to have a Medical Director?
- When a patient is transferred to an inpatient facility, what type of paperwork needs to be completed?
- If the patient remains in the hospital on the last day of the certification period what should the agency do?
- Can the physician participate in the Professional Advisory Committee (PAC) by telephone or does he/she have to be physically present at the meeting?
- Physicians are no longer being issued UPINs. Is the UPIN still required on the OASIS even if the provider has an NPI? If the physician reports no UPIN is there a dummy number to enter in that field on the OASIS?
- Could someone from CMS please address how to answer MO520 with someone who has a Nephrostomy Tube?
- Can we interpret MO520 to mean if the urinary diversion is pouched with an ostomy appliance it is not a catheter but if it is accessed with a tube or catheter (external or otherwise) then the patient has a catheter? And just to clarify......what about the patients with continent urinary diversions? They have a stoma but are accessing with intermittent catheterizations. They have catheters as well, right?
- If TJC/CHAP are surveying me, do I still need to put in for readiness to the State?
- Why is the State surveying my agency?
- When do I do my OASIS test transmission?
- Do I notify the State when I change DON's?
- Who do I need to tell if I change telephone numbers or address?
- When do I need to renew my State License?
- What is the difference between contact and clock hours?
- How do I request a consulting visit from Compliance Review Services?
- How do I sign up for an in-house class at Compliance Review Services?
- How many patients must we have for a Licensed Home Health survey?
- Does Compliance Review Services help get patients for our agency?
Can an outpatient therapy do therapy visits on a home health patient and the home health provide the skilled nursing and aide services only?
[back to top]The home health must provide all services to the patient and bill for those services. A patient CANNOT go to outpatient therapy and have the therapy company bill Medicare.
An agency can contract with an outpatient therapy clinic and then pay the clinic for the visits and bill Medicare directly or the agency can discharge the patient if they insist on going to outpatient therapy and not utilizing who the agency has contracts with.
Our patient went into the hospital and is now hospitalized during the time period the recertification is due. What should we do?
[back to top]The agency has 2 options available to them.
OPTION ONE: Discharge the patient and readmit them once out of the hospital and start a new consent, and admission, and chart.
OPTION TWO: Write a hold order stating the patient is in the hospital. Make sure you document daily follow ups to the hospital to show coordination of care. When the patient comes out of the hospital then you must do a resumption of care /lusive of updated aide care plan, updated medication listing, new 485 starting with the date they resumed care, conduct the 60 day summary at the 60 day mark even if they are in the hospital and you state such in the 60 day summary. All paperwork needs updated and competed. It is NOT acceptable to state "resume previous orders" under any set of circumstances.
As a home health agency am I required to do TB skin testing on all my employees?
[back to top]The agency has 2 options available to them.
There is not a specific State rule or Federal regulation that requires home health agency employees to have TB skin test, however the agency is required to ensure compliance with the Communicable Disease Prevention and Control Act, Health and Safety Code, Chapter 81 as part of their Infection Control policy. The CDC guidelines changed in 2007 /luding home health agencies. In addition, an agency must have a policy on how they will prevent the spread of communicable diseases, which generally includes TB.
Reference: State HCSSA Rule 97.285 Health and Safety Code, Chapter 81
Does a home health agency have to have all their employees CPR certified?
[back to top]The agency has 2 options available to them.
There is not a regulation or rule requirement to have employees CPR certified, however as part of the Advance Directive policy the agency must include a clear and precise statement of any procedure the agency is unwilling or unable to provide. So if the agency does not require all their employees to be certified in CPR they must inform the patient/family members of this in accordance with the Advance Directive policy. In addition, it is an expectation of clients, patients, and family members that if they are receiving professional home health services that the staff are CPR certified. It is your job to tell them if you are not. Most employers in the health care industry DO require their health care staff members who do direct patient care to be CPR certified.
Reference: State HCSSA Rule 97.283
If a home health agency offers home health aide services and these services are provided by a registered nurse, does the agency have to have a registered nurse supervise the registered nurse making the home health aide visits?
[back to top]The agency has 2 options available to them.
The agency can have a registered nurse perform home health aide services, but the agency must also ensure home health aide supervision is performed every two weeks by another registered nurse.
Reference: CFR 484.36(d)(3)
Is a home health agency required to have a Medical Director?
[back to top]The agency has 2 options available to them.
Medical Directors are required for Hospice agencies, however not for home health agencies. Home Health Agencies are required to have a Medical Advisor as a member of the Professional Advisory Committee (PAC).
Reference: CFR 484.16 and CFR 484.54
Can the physician participate in the Professional Advisory Committee (PAC) by telephone or does he/she have to be physically present at the meeting?
[back to top]The agency has 2 options available to them.
The physician must be physically present at the agency's PAC meeting and the agency should ensure that all committee members sign the attendance roster and include this roster with the documented dated meeting minutes. An exception would be if the physician had some type of emergency and could not attend the meeting, then a 1:1 face to face meeting with the physician going over everything in the meeting would need to be done.
Reference: CFR 484.16
When a patient is transferred to an inpatient facility, what type of paperwork needs to be completed?
[back to top]The agency has 2 options available to them.
When a patient is transferred to an inpatient facility, a transfer OASIS must be completed within 48 hours of the agency's knowledge of the inpatient facility admission. The agency has 2 options RFA6-transfer to an inpatient facility-not discharged from the agency or a FGA7-transfer to an inpatient facility-discharged from the agency. The transfer OASIS data set must be encoded, entered into HAVEN or haven like software, locked in and transmitted to CMS within 30 days from the date the assessment was performed-we recommend transmission within 7 days.
If the patient remains in the hospital on the last day of the certification period what should the agency do?
[back to top]The agency has 2 options available to them.
If the patient remains in the hospital on the last day of the certification period-the agency again has 2 options. You choose to do an internal discharge from the agency (no further OASIS assessment required)-only a discharge summary and discharge order to the MD. The agency DOES NOT have to discharge the patient-when the patient returns home from the inpatient stay the agency performs a RFA3-Resumption of Care OASIS within 48 hours of discharge from the inpatient facility with the focus being on the present certification period and a Plan of Treatment (485) orders developed from this assessment. The SOC date will not be affected. The OASIS data set must be encoded, entered into HAVEN (or HAVEN like software), locked in and submitted to CMS within 30 days from the date of assessment-again we recommend transmission within 7 days. Please note that you will receive a warning message that the assessment is late when you transmit the data.
It is up to the agency and your policy as to whether you write "Hold" orders for the inpatient facility stay but communication and coordination of care with the inpatient facility documentation must be present in the clinical record. If the agency does not discharge the patient with transfer to an inpatient facility you must have a Post Hospital orders written to resume all previous Home Health orders and any/all new orders resulting from the inpatient stay (medications, treatments, frequencies of disciplines) with any/all new or changed goals.
REMEMBER to check your agency's policy for these assessments-if your policy states you discharge on the last day of the certification period- you must follow your policy or re write your policy to follow the CMS clarifications on this subject.
Physicians are no longer being issued UPINs. Is the UPIN still required on the OASIS even if the provider has an NPI? If the physician reports no UPIN is there a dummy number to enter in that field on the OASIS?
[back to top]"The NPI is a claims processing issue. As such, we do not have to require its collection on OASIS in May. We do not have the resources to make the change to OASIS for one item at this time. In the future, we will probably add an OASIS item for the HHA's NPI. It looks like we will continue to collect the HHA's ID number, M0010. This is the current "Provider Number", to be renamed the CCN. For now, we will require /lusion of the HHAs NPI in the header and body of the transmission record, QTSO memo to be released later, a one time change."
However, agencies may enter the physician NPI in M0072 since there is already sufficient space to accommodate the NPI. It is true that assignment of UPINs has been suspended.
CMS email:
"Our OASIS item, M0072, Primary Referring Physician ID has always had 10 digits. This is very lucky because the NPI has 10 digits. In the past we have required the physician UPIN number. This will easily translate to NPI. Currently there are no edits applied to M0072. We (OASIS) will not have any edits on this field in the future. That means you can put the NPI in M0072 with no programming changes."
MA Episode Payments and PPS Reform
We learned from CMS that the current version of the PPS pricer being used by MA plans that pay episodically (Medicare Private FFS Plans only) does not allow for input of the treatment authorization code. Therefore, they are not capable of making adjustments to final claim payment when the number of therapy visits differs from that indicated by the HIPPS code on the RAP. Until this is corrected, it is essential that home health agencies make adjustments by canceling and resubmitting RAPs with the correct HIPPS code when the number of therapy visits actually delivered differs from that on the RAP.
CMS has completed its review of their PPS products and will be issuing a revised version of the PC pricer that will have the treatment authorization code and adjustment functionality in the near future. Private FFS MA plans should install this newer version once it becomes available.
Could someone from CMS please address how to answer MO520 with someone who has a Nephrostomy Tube?
[back to top]The nephrostomy tube is not discussed directly in the RESPONSE-SPECIFIC INSTRUCTIONS area or Q&As. It does state that if the patient has an ostomy for urinary drainage (e.g. ileal conduit/urostomy, ureterostomy) mark response "0", no /ontinence or catheter. Many are interpreting this to mean anything ending in "ostomy" is not a catheter. The problem with this logic is that it would exclude a SP catheter because it is actually a cystostomy". It is also confusing because no-one refers to it as a nephrostomy catheter but a tube.
Can we interpret MO520 to mean if the urinary diversion is pouched with an
ostomy appliance it is not a catheter but if it is accessed with a tube or
catheter (external or otherwise) then the patient has a catheter? And just
to clarify......what about the patients with continent urinary diversions?
They have a stoma but are accessing with intermittent catheterizations.
They have catheters as well, right?
[back to top]CMS Response: When a patient has urinary diversion, with or without a stoma, that is pouched for drainage, the appropriate M0520 response would be "0-No /ontinence or catheter". The appropriate response for a patient with urinary diversion, with or without a stoma, that has a catheter or "tube" for urinary drainage would be "2 -Patient requires a urinary catheter (i.e., external, indwelling, intermittent, suprapubic)." A patient that requires intermittent catheterization would be represented by Response 2, even if they have continent urinary diversions.
If TJC/CHAP are surveying me, do I still need to put in for readiness to the State?
[back to top]The state regulation requires a Home Health or Hospice facility notify of readiness for initial survey prior to an initial license becoming 6 months old. The requirement is the actual notification, not that the survey is performed at the 6 month mark. Readiness for survey is done by completing and submitting DADS form 2020. Failure to do so, even if you are waiting an accreditation survey may affect your license renewal process when the time comes to renew. Even though you are seeking accreditation or have accreditation you must always follow DADS regulations, without a license from the state you cannot operate a Home Health agency or Hospice facility in the State of Texas and without a license, accreditation becomes a moot point.
Why is the State surveying my agency?
[back to top]The Texas Department of Aging and Disability Services (DADS) can visit your agency unannounced at any time after your license had been issued by them. It is not likely that DADS would survey you prior to your notification of readiness. You could be surveyed by DADS at anytime for a complaint that any individual or business has made regarding your business or any part of your business under a DADS license A complaint would certainly result in a survey. Your license when issued will be good for 24 months, renewing your license with DADS may also result in a survey. Even if you have recently undergone an accreditation survey, DADS may not be aware of that fact and may conduct a survey regardless. The motto of any licensed facility therefore should be, stay survey ready at all times.
When do I do my OASIS test transmission?
[back to top]After you have received the letter from CMS (Centers for Medicare and Medicaid Services) stating your application has been forwarded to the State you need to contact the OASIS help desk and request a user name and password be issued to you in order to conduct a test transmission. The State will mail you the user name and password in the US mail. You have a defined period of time to complete the test transmission to the State. This is generally when this is done. The test transmission must be done prior to the initial medicare survey.
Do I notify the State when I change DON's?
[back to top]It is not required to notify the State of a change in DON. It is recommended by our consulting firm that you do so as a way to communicate with the State. If you have changes in key management personnel, CMS must be notified. The DON position is considered to be a key management position.
Who do I need to tell if I change telephone numbers or address?
[back to top]The state regulation requires an agency to notify DADS within five days after a change in the agency'’s telephone number or after a change in the agency'’s operating hours.
An Agency must notify DADS 30 days before relocating to a new address.
Joint Commission or CHAPS must be notified if an agency has accreditation/certification with one of them.
CMS must be notified if an agency has Medicare certification.
When do I need to renew my State License?
[back to top]An agency must submit to DADS a completed renewal application along with all required supporting documentation postmarked no later than 45 days before the expiration date of the current license.
What is the difference between contact and clock hours?
[back to top]Contact hours are educational hours for professional people (RN`s for example) that have been approved and are required by professional boards; Clock hours are educational hours that a non licensed /professional can attend, or are required to attend. Clock hours are a requirement of DADS as part of their pre appointment and annual ongoing education for a Home Health or Hospice Administrator and Alternate Administrator.
How do I request a consulting visit from Compliance Review Services?
[back to top]On compliance Review Services'?web site under the navigation bar located on the left side of the home page, click on '“scheduling'? Print the '“scheduling request form'? complete the form and return to the office via fax 832-237-2505. If necessary you may also contact the office directly to request a consulting visit. Please remember the scheduling of consultant visits is done 30 days in advance.
How do I sign up for an in-house class at Compliance Review Services?
[back to top]On Compliance Review Services'?web site under the navigation bar click on '“Training Center'?and review the classes available and how to sign up. If necessary you may also contact the office directly to sign up for an in-house class.
How many patients must we have for a Licensed Home Health survey?
[back to top]The agency must have serviced one patient before notifying the State of its readiness. Remember that one patient does not have to be an active patient for the License Home Health survey to take place.
Does Compliance Review Services help get patients for our agency?
[back to top]Compliance Review Services does not help agencies obtain patients. The agency must do their own marketing and secure their own patients through contacts that they may have. A few recommendations as to where to market would be: Nursing Home Social Workers, Hospital Discharge Planners, Physician Offices, Clinics, and other Health Care Industries such as Assisted Living Facilities.
