Home Health Update - February 2002
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of BQA 02-008 (PDF, 9 KB)
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Date: February 26, 2002 DSL-BQA-02-008
To: Home Health Agencies HHA 4
From: Jan Eakins, Chief, Provider Regulation and Quality Improvement
Section
Cc: Sue Schroeder, Director, Bureau of Quality Assurance
The purpose of this memorandum is to provide you with information
received from the Centers for Medicare and Medicaid Services (CMS) related
to a modification in their policy related to the types of qualifying
services provided directly by employees of a Medicare approved home health
agency (HHA). The CMS memorandum S&C-02-13 modifies guidance published
at section 2180 of the State
Operations Manual Transmittal 25 (exit DHFS; PDF), which became
effective April 15, 2001. This transmittal was previously distributed to
all home health agencies via DSL-BQA-01-016
in March 2001.
A copy of the CMS transmittal S&C-02-13 is attached for your
reference [below].
Questions related to this information can be directed to the following
individuals:
-
Karen Turnure, Home Health Compliance
Specialist
Turnuka@dhs.state.wi.us, 608-266-7782
-
Barbara Woodford, Home Health Nurse
Consultant
(replaced by Marianne
Missfeldt, (715) 836-4036).
-
Juan Flores, Health Care Regulatory
Southern Unit Supervisor
(replaced by Jan Heimbruch, heimbjl@dhs.state.wi.us
(608) 243-2086).
DEPARTMENT OF HEALTH & HUMAN SERVICES
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
S&C-02-13
DATE: January 7, 2002
FROM: Director, Survey and Certification Group
SUBJECT: Services Provided by Home Health Agencies (HHAs)
TO: Associate Regional Administrators, DMSO, State Survey Agency
Directors
The purpose of this memorandum is to notify regional office and state
agency personnel of a modification in our policy related to the types of
qualifying services provided directly by employees of a Medicare approved
home health agency (HHA). We are revising our policy, at section 2180 of
the State Operations Manual (SOM), to require that a Medicare approved HHA
must provide at least one qualifying service (i.e., skilled nursing,
physical therapy, speech language pathology, occupational therapy, medical
social services, or home health aide services) directly and in its
entirety by employees of the HHA. The other qualifying services and any
additional services may be provided either directly or under arrangement.
In the State
Operations Manual Transmittal 25 (exit DHFS;
PDF), effective April
15, 2001, we modified our guidance at section 2180 to require HHAs to
provide one of three qualifying services (i.e., skilled nursing, physical
therapy, or speech language pathology) directly by employees of the HHA.
The other services provided by an agency could be provided directly or
under arrangement.
Following the effective date of Transmittal 25, we received inquiries
regarding the rationale for this policy change and the associated provider
burden. We recognize this survey and certification qualifying service
policy revision required some HHAs to make changes in how they provide
services and these changes in HHA operations would take some time to
implement. Based upon our review of historical Medicare home health
program documents and the reported and unanticipated HHA operational
implications of this policy change, we believe it is necessary to revise
our policy and broaden the types of services that may be provided directly
by an HHA.
Effective Date: The information contained in this memorandum is
current policy and is in effect.
Training: This policy should be shared with all survey and
certification staff, surveyors, their managers, and the state/regional
office training coordinator.
I hope this information is helpful to you. If you would like to discuss
this further, please contact your regional office representative for HHAs.
/s/ Steven A. Pelovitz
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