ROUTINE MEDICAL SUPPLIES

There exists much confusion regarding routine medical supplies in the HHA industry. The PPS rule states that the cost of routine medical supplies is bundled into the HHA’s PPS reimbursement. As such, HHA’s may not bill separately for routine supplies. Routine supplies are “supplies that are customarily used in small quantities during the course of most home care visits. Routine supplies would not include supplies specifically ordered by the physician or are essential to HHA personnel in order to effectuate the plan of care.”

Examples of supplies which are usually considered routine medical, but are not limited to:

A) Dressings and Skin Care
B) Infection Control Protection
C) Blood Drawing Supplies
D) Incontinence Supplies

If the above items are required in quantity, for a recurring need, these supplies may be considered non-routine and this may be a billable supply. This should be confirmed with your local Intermediary prior to billing.

NEW CHANGE OF OWNERSHIP/TRANSFER OF STOCK PROHIBITIONS

Effective, January 1st, 2010 all HHA transfers of stock and those that are defined as a Change of Ownership (CHOW), which occur prior to the expiration of 36 months from the receipt of the HHA’s Medicare certification, will require that the acquiring party or entity enroll as a new provider via a CMS 855A and undergo a state survey or accreditation. This will cause a gap in billing from the time CMS-RO pends all claims of the deactivated HHA until the new provider agreement is activated.

MANAGEMENT AND EVALUATION

The 2010 PPS Rule clarifies the rule that in the house health setting, management and evaluation of a patient care plan is considered a reasonable and necessary skilled service only when underlying conditions or complications are such that a registered nurse can ensure that essential non-skilled care is achieving its purpose. (42 C.F.R. 409.42(c)(1)(i))
Patient Education Services
The 2010 PPS Rule clarifies when patient education services constituted skilled services would be deemed to no longer be needed when it became apparent, after a reasonable period of time, that the patient, family, or caregiver would not be trained. Further teaching and training would cease to be reasonable and necessary in this case and would cease to be considered a skilled service. The services for teaching and training would be considered to be reasonable and necessary prior to the point that it became apparent that the teaching on training was unsuccessful.

2010 HHA PPS OUTLIER CAP AND NEW HHA CONGRESSIONAL CUTS

Beginning calendar year 2010, CMS will cap home health outlier payments at 10% per HHA and target total aggregate outlier payments at 2.5% of all HH PPS payments. This is an agency level cap such that in any given calendar year, an individual HHA would receive no more than 10% of its total HH PPS payments in outlier payments.
In a 12/05/09 New York Times article, the impact of this legislation has been a topic of interest during the first week of Senate debate. Under Congress’s new legislation to insure more than 30 million Americans, home care would be hit disproportionately hard. Home care currently accounts for 3.7% of the Medicare budget but would take a 10.2% hit by the House bill and 9.4% hit by the Senate bill. This translates into a $55 billion reduction over 10 years in Medicare spending on home health services under the House bill and a $43 billion reduction under the Senate bill.