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CMS proposal would eliminate homebound requirement for Medicaid beneficiaries

A recently proposed rule (CMS 2348-P) would change the definition of homebound for the purposes of determining eligibility for Medicaid-covered home health services.

Homebound status, along with medical necessity and a physician’s plan of care, is one of three basic requirements for eligibility of homehealthcare, Jackie Birmingham, RN, MS writes in Curaspan Connections. Birmingham, explains that case managers typically screen for homebound status first when assessing patients for levels of post-acute services.

CMS considers patients homebound if they leave home infrequently, for short periods of time, or for medical treatment. Patients must meet the homebound requirement to qualify for Medicare-covered home health services, but the proposed rule would eliminate homebound status as a requirement to qualify for Medicaid-covered home healthcare.

The rule also proposes eliminating the restriction that home health services must be provided in a patient’s home.

Birmingham notes that expanding home health services to include those administered outside the home blurs the line between home care and community care. This makes a case manager’s job more difficult, she says.

A sharper distinction between home care and community care will facilitate application of that care. A community-based benefit can be provided within the existing infrastructure of home healthcare, but it requires more complex administration by case managers and more active involvement by recipients, she explains.

Services for a specific beneficiary may require scheduling at more than one location. For example,  recipients scheduled to receive nursing visits at their place of employment who are then unable to work that day won’t be in the right place at the right time.

CMSseeks public comment on the proposed rule. Submit comments at www.regulations.gov/#!documentDetail;D=CMS-2011-0133-0002.  The deadline for comments is September 12, 2011.

Face-to-face requirement

Please take a moment to let us know how the face-to-face encounter requirement has affected your organization. Please feel free to elaborate on any challenges you have encountered in the comments section below.


Meet face-to-face requirement for home healthcare services

The new year is upon us and with it comes a new requirement for Medicare patients who require home healthcare services.

A provision of the Affordable Care Act mandates that certifying physicians document that they or an allowed non-physician practitioner (NPP) has had a face-to-face encounter with the patient before certifying eligibility for the home health benefit. This encounter must occur within 90 days before the start of care or 30 days afterward.

The goal of the new rule is increasing physician involvement in patient care, according to Jackie Birmingham, RN, MS, is vice president of regulatory monitoring and clinical leadership at Curaspan Health Group. Birmingham wrote about the new requirement in the current issue of Curaspan Connections.

Birmingham writes:

I’m old enough to remember house calls, and while I know they won’t return, I still believe physician involvement—contact with patients—should be at the very foundation of health-care delivery. Apparently lawmakers, looking for (more) ways to cut costs and increase accountability, agree but found that’s not always the case. So, we now have this new regulation that micro-manages providers.

Hospital case managers can meet this requirement in the following ways:

  • Determine who will perform the face-to-face encounter as part of the discharge process
  • Develop a policy for documenting encounters and transmission of documentation to home-health agencies.

Remember that without certification, there’s no reimbursement. Home healthcare agencies will be looking for documentation; otherwise, they may not accept patients Birmingham writes. This can cause throughput problems as patients linger in hospitals, or patients may be sent home without services, only to be readmitted.