CMS recently clarified that hospice and skilled nursing facility medical directors and administrators are always considered managing employees for Medicare provider enrollment purposes. You must report all current managing employees. If you haven’t reported a medical director or administrator, report them now. See the Medicare Program Integrity Manual: CY 2024 Home Health Prospective Payment System Updates (PDF) MLN Matters Article for more information.
CMS issued a CY 2024 Home Health Prospective Payment System Rate Update final rule to update Medicare payment policies and rates for home health agencies. See a summary of key provisions effective January 1, 2024.
In the skilled nursing facility industry, there is a three-day hospitalization rule that states that if a patient has spent at least three full days in a hospital, they qualify for skilled nursing facility stays. Unfortunately, this rule does not apply to home health.
In the PDGM model, institutional credit is given to a patient’s 30-day payment when the patient has been officially admitted to a hospital, skilled nursing facility, LTCH, rehab, or psych facility, and is discharged with a discharge date within 14 days before the start of the upcoming 30-day payment period in home health. It’s crucial to confirm that the patient’s stay was an official admission to the facility, and you must have documentation for the discharge date.
On the 30-day final claims, either code 61 or 62 can be used, based on the type of facility the patient was discharged from. Code 61 is for discharge from an acute care hospital, while code 62 is for discharge from a SNF, LTCH, rehab, or psych facility. By including these codes on the home health claim, institutional credit for that 30-day payment period can be received, even if CMS or the Medicare MAC does not have a corresponding facility claim in the system. If a code 61 or 62 is not included on the claim and there is no facility claim in the system, institutional credit will not be granted. (Supposedly, a reconciliation process exists where if an institutional claim is found, the Home Health Agency will receive credit, though this should not be relied on.)
Additionally, having the code 61 or 62 on the claim to automatically receive institutional credit requires supporting documentation within the chart. This documentation is needed for medical review purposes to confirm the official admission to the facility and provide evidence of the discharge date.
When constructing your 30-day payment periods, if a patient who has already been on home health services is transferred to a facility and is officially admitted there, a transfer takes place. Upon returning home from that facility, if the discharge date from the facility falls within 14 days before the start of the upcoming 30-day payment period, institutional credit should be received for that forthcoming 30-day claim.
It’s important to remember that if the patient doesn’t return home until the next 30-day payment period, the payment period will not receive institutional credit. For instance, if the patient returns home on day 35, which falls within the second 30-day period, the patient will have to be discharged and readmitted to home health to qualify for institutional credit in the HIPPS code calculation. Institutional credit for a patient is only given when they have been discharged from an SNF, LTCH, rehab, or psychiatric facility and it marks a brand new start of care for home health.