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Test your knowledge answers:

1) The standard for the drug regimen review is not new; it was included in the previous Conditions of Participation (CoP) under the plan of care requirements. The comprehensive assessment must include a review of all medications the patient uses to identify any potential adverse effects and drug reactions, including ineffective drug therapy, significant side effects, drug interactions, duplicate drug therapy, and noncompliance with drug therapy. The scope of the drug regimen review has thus been narrowed from the previous CoP. Each agency must determine the capabilities of current staff members to perform comprehensive assessments, taking into account professional standards or practice acts specific to your state. No specific discipline is identified as exclusively able to perform this assessment. Only RNs, PTs, OTs, and SLPs are qualified to perform comprehensive assessments.

It is acceptable for an RN in the office to collaborate on the medication regimen review in a situation where a therapist completes the comprehensive assessment. If areas of concern are identified, the agency must notify the physician and as appropriate obtain orders for any nursing intervention to further assess and resolve issues and educate the patient regarding medication changes and management.

2) As stated in the Q3 of the April 2020 CMS Quarterly OASIS Q&As: There is no change in the OASIS guidance in how agencies may use M0100 RFA 6 and 7 when a home health patient is admitted for an inpatient stay. In the event that a patient had a qualifying hospital admission and was expected to return to your agency, you would complete RFA 6 – Transferred to an inpatient facility – not discharged from agency. If the patient was not expected to return to your agency after this inpatient hospital stay, you would complete RFA 7- Transfer to an inpatient facility- patient discharged from agency.

However, if the patient requires post-acute care in a SNF, IRF, LTCH, or IPF during the 30-day period of home health care, CMS expects and recommends (but does not require) the home health agency to discharge the patient by completing the RFA-7 (Transfer to an inpatient facility patient discharged from agency) and then to readmit the patient with a new Start of Care upon return to home care.

If the home health agency decides to complete an RFA-6 (Transfer to an inpatient facility- patient not discharged from agency), the home health agency will need to complete an RFA-3 (Resumption of Care) upon return to home care.

3) Starting on page 26 of the Home Health Care CAHPS® Survey Protocols and Guidelines Manual, Version 12.0, January 2020:

Patient Eligibility Requirements HHAs should include in the files submitted to survey vendors all patients who meet the HHCAHPS Survey eligibility criteria (asterisked criteria are explained more fully in paragraphs that follow):

• Patients who are at least 18 years of age by the end of the sample month;

• Patients whose home care was paid for by Medicare or Medicaid. This includes patients who are enrolled in Medicare fee-for-service plans and those enrolled in Medicare Advantage (MA) plans or Medicaid managed care health plans.

• Patients who had at least one home health visit for skilled nursing care, physical therapy, occupational therapy, or speech therapy during the sample month*;

• Patients who had at least two home health visits for skilled nursing care, physical therapy, occupational therapy, or speech therapy during the lookback period (includes the sample month and the preceding month)*;

• Patients who are not deceased;

• Patients who are not currently receiving hospice care; and

• Patients who received home visits for services other than routine maternity care in the sample month.

4) Medicare Conditions of Participation (CoP) for home health are separate from the rules governing the Medicare hospice program. Care delivered to a patient under the Medicare home health benefit needs to meet Federal requirements put forth for home health agencies, which include OASIS data collection and reporting for skilled Medicare and Medicaid patients. Care delivered to a patient under the Medicare hospice benefit needs to meet the Federal requirements put forth for hospice care, which does not include OASIS data collection or reporting.

However, if a Medicare patient is receiving skilled terminal care services through the home health benefit, OASIS applies.

5) If the individual was determined to not be eligible for services, the patient would not be admitted for care by the agency, and no comprehensive assessment or OASIS data collection would be required. No data would be transmitted to the OASIS system.

6) According to the comprehensive assessment regulation, when both disciplines are ordered at SOC, the RN would perform the SOC comprehensive assessment. Either discipline may perform subsequent assessments.