You Asked:
We are seeking clarification around the regulatory expectation for updating a patient’s physician if the patient is not desiring to be admitted to home health within 48 hours of the referral order. We have notified the physician via fax and documented the notification. Is this allowed or does the staff need to speak to a live person at the doctor’s office?
We Answered:
Please see the bold area below in the home health conditions of participation. The regulation states the Home Health Aide (HHA) must contact the physician and request a change in the start of care date. It does not specify how you contact the physicians, but the home health agency would want to obtain a new start date as soon as possible and document the communication with the physician. If the best mode of communication with a physician is to reach them by fax, that would be acceptable if they are able to provide a new start date for the patient. If the physician does not respond via fax, then the agency should call the physician as a new start date needs to obtained and documented in the medical record.
484.55(a) Standard: Initial assessment visit.
G514
(Rev. 182, Issued: 09-28-18, Effective: 09-28-18, Implementation: 09-28-18)
Interpretive Guidelines §484.55(a)(1)
For patients receiving only nursing services or both nursing and rehabilitation therapy services, a registered nurse must conduct the initial assessment visit. For patients receiving rehabilitation therapy services only, the initial assessment may be made by the applicable rehabilitation skilled professional rather than the registered nurse. See §484.55(a)(2).
The initial assessment bridges the gap between when the first patient encounter occurs and when a plan of care can be implemented. “Immediate care and support needs” are those items and services that will maintain the patient’s health and safety through this interim period, i.e., until the HHA can complete the comprehensive assessment and implement the plan of care. “Immediate care and support needs” may include medication, mobility aids for safety, skilled nursing treatments, and items to address fall risks and nutritional needs.
The clinical record must demonstrate that homebound status/eligibility for the Medicare home health benefit was determined and documented during the initial visit.
An HHA that is unable to complete the initial assessment within 48 hours of referral or the patient’s return home, shall not request a different start of care date from the ordering physician to ensure compliance with the regulation or to accommodate the convenience of the agency.
In instances where the patient requests a delay in the start of care date, the HHA would need to contact the physician to request a change in the start of care date and such change would need to be documented in the medical record.