Home Health and Hospice providers seeking initial accreditation with deemed status

Mar 7, 2012

All Home Health and Hospice providers seeking initial accreditation with deemed status (CHAP performing the site visit necessary to complete the Provider Enrollment process) should be aware of the following CMS information.  This critical information will help you plan and avoid unnecessary delays in obtaining your CCN.  The CMS manuals are an abundant source of information; we have included the citation and reference to the CMS manuals here to assist you in further understanding these topics.

For All New Providers

5.5.5 - State Surveys and the CMS-855A    
(Rev. 272; Issued:  11-07-08; Effective/Implementation Date:  12-08-08)

In general, information on the CMS-855A is still considered to be valid notwithstanding a delay in the State survey.  However, the provider will be required to submit an updated CMS-855A application to the contractor if:
• The contractor becomes aware of such a delay;
• The delay is the fault of the provider; and
• At least 6 months have passed since the contractor sent its recommendation for approval to the State.
If these criteria are met, the contractor shall send a letter to the provider requesting an updated CMS-855A.  The application must contain, at a minimum, any information that is new or has changed since the recommendation for approval was made, as well as a newly-signed certification statement.  If no information has changed, the provider may instead submit: (1) a letter on its business letterhead stating as such, and (2) a newly-signed CMS-855A certification statement.

NOTE: If the applicant is an HHA, it must resubmit capitalization data as required by section 12 of the CMS-855A irrespective of whether any of the provider’s other CMS-855A information has changed.  To illustrate, if no CMS-855A data has changed, the HHA must submit the letter, capitalization data and the signed certification statement.

If the provider fails to furnish the requested information within 60 days, the contractor shall submit a revised letter to the State that recommends denial of the provider’s application.


(Citation source: CMS Manual 100-08 Program Integrity Manual chapter 10, section 5.5.5)

For New Hospices

 
2086C – Move after Certification Survey
(Rev. 73, Issued: 12-02-11 Effective: 12-02-11, Implementation: 12-02-11)


Requests for initial certification cannot be processed to completion if a prospective provider moves to a new location after it is surveyed and/or deemed to meet the CoPs by a national AO with deeming authority. If a prospective provider moves after its location has been surveyed and/or accredited but prior to a certification determination by CMS, the prospective provider’s application for certification becomes incomplete. Absent a survey of the new location to which the prospective provider has moved, CMS is unable to determine whether applicable program requirements are met at the new location, and therefore is prevented from completing its review of the pending application. In these circumstances, CMS advises the prospective provider that its application is incomplete. Such an incomplete application is held in abeyance pending receipt of a report of survey of the current location from the SA or a national AO with deeming authority meeting the requirements of and approved by CMS. The decision to hold an incomplete application in abeyance does not qualify as an initial determination as defined in 42 CFR 498.3.

(Citation source:  CMS Manual 100-07 State Operations Manual Chapter 2 section 2086)

For New Home Health Agencies

2210E - Instructions for Handling Medicare Patients in HHAs Seeking Initial Certification
(Rev. 1, 05-21-04)

If the HHA is confident that it has met all CoPs and all other Medicare requirements at the time the initial survey is completed, the HHA is advised to do a new SOC assessment, (RFA 1) on each of its Medicare patients at the first billable visit after the onsite survey. The HHA should delay encoding and transmitting the assessment until the Medicare provider number is assigned.

Once the provider number has been assigned, the HHA can go back and encode the collected OASIS information, obtain the necessary payment system codes for billing under PPS, and transmit the information to the OASIS State System as production (i.e., “live”) data. The date of this assessment will become day 1 of the HHA’s first 60-day episode under Medicare, as long as the assessment was done in conjunction with a billable visit. Warning messages related to noncompliance with timing requirements are unavoidable and are to be expected in this situation.

If compliance (i.e., the effective date) is not the date of the onsite survey, it will be based on D.2. above, as further outlined in §2780. The HHA should, again, do a new SOC assessment (RFA 1) on each of its Medicare patients at the first billable visit after the anticipated date of compliance, delay encoding and transmitting the assessment until the Medicare provider number is assigned, and continue as outlined in the paragraph above. That is, the HHA should go back and encode the collected OASIS information, obtain the necessary payment codes for billing under PPS, and transmit the information to the OASIS State System as production data. As above, warning messages related to noncompliance with timing requirements are unavoidable and are to be expected in this situation.

If the new HHA did not conduct a SOC (RFA 1), ROC (RFA 3), or Follow-up (RFA 4) OASIS assessment during the time between the effective date for Medicare participation and the date the HHA learns of its approval, the HHA should conduct a SOC assessment, as soon as possible. This assessment can be used to generate the payment code used for billing under Medicare. The SOC date should reflect a date that is consistent with the first billable visit after the effective date for Medicare participation, as stated above.

2210F - Instructions to New HHAs Concerning all Other Patients
(Rev. 1, 05-21-04)

For all other patients treated by the HHA (i.e., non-Medicare patients), if a new start of care date is not required by the patient’s pay source, the HHA should encode and transmit all OASIS assessments as required by current regulation that were collected after the effective date of Medicare participation. These assessments should be submitted in the production mode using the newly assigned provider number. The HHA should continue with the OASIS assessment schedule already established based on the patient’s admission date.

(Citation source:  CMS Manual 100-07 State Operations Manual Chapter 2 section 2210)

Please feel free to contact your Customer Relations Representative or Regional Director if you have questions about how these may apply to you.  You can access the CMS internet manuals through this link:  http://www.cms.gov/Manuals/IOM/list.asp

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