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Home Health & CMS COVID-19 Flexibilities: Read the Fine Print

Currently home health agencies are fighting to stay productive and profitable in the PDGM operating environment, now compounded by the COVID-19 national emergency. While this week’s CMS COVID-19 rulings feature many great new proposals, home health agencies may remain feeling somewhat puzzled about the practical implications of what was actually released. HealthPRO-Heritage is here to help break down the confusion. The below chart provides insight on what these new proposals actually mean for home health agencies going forward. Here is what we know so far:

Updated Medicare Regulatory Requirements:

Impact to Home Health Agencies



2% take back being waived from 5/1 through end of year.  Will impact 30-day payment periods that begin 5/1 through 12/31/20.


HH Audit Activity

All non-fraud related audit activity (inclusive of ADRs, TPE, etc.) is being suspended during this national emergency period. Program Integrity audits will continue for suspected fraud. 


Our RCD Suspension

RCD suspended as of 3/26/20 through national emergency period.  Will be paused in IL, OH, and TX and will delay initiation in NC and FL.





All telehealth visits must be clearly outlined in the HH plan of care and the physician must agree.  Does not replace the necessary in-person visits.  Telehealth visit does not count towards LUPA threshold for reimbursement.  Telehealth visit requires 2-way audio-visual communication between clinicians and patients and must be documented as such. Any home health clinician can provide a telehealth visit as long as it is allowed by your state practice act.


Homebound Status

Patients who are certified by the physician to be at risk of infection by leaving home are now considered homebound.


Non-Physician Practitioner Certification

NPs, PAs, and CNSs can establish, certify, and re-certify HH services if allowed by state practice and licensure acts.  For further guidance, check with your state practice act. This will continue beyond pandemic emergency. 


Medicare Advanced Payment

Agencies can file for up to 120 days of anticipated payment.  Must ensure sensible and defensible estimate in order to avoid repayment situation. 




Initial Evaluation Requirement

This evaluation is required within 48 hours, but can be completed remotely or via medical review rather than an in person visit.  Gives agencies flexibility to meet 48-hour requirement, but does not include the comprehensive assessment and/or OASIS requirements.  This is independent of comprehensive assessment requirement and does not allow SOC visits to be completed remote. 


OASIS Transmission

Flexibility is being provided in meeting 30-day OASIS transmission requirements during national emergency period. 


OASIS Completion

The 5-day window that is required for OASIS completion has been extended to 30 days during national emergency period. 


Home Health Aide Supervision

The current requirement of Home Health aide supervision every 14 days is being waived during the national emergency period.  It is recommended that remote visits be conducted as much as possible. 


F2F Encounters

A F2F encounter is still required, but it can be completed via a telehealth visit vs. an in-person visit with the physician or non-physician practitioner. 


To avail themselves of these new tools, agencies need to be diligent in managing their reimbursement, visits, and productivity throughout this COVID-19 emergency.  HealthPRO Heritage has the tools and resources, such as clinical outcomes tracking, utilization management processes, and PDGM groupings-based clinical pathways including a newly added Pulmonary Pathway to provide evidence based support for COVID-19 patients.  Please reach out at ClinicalStrategies@healthpro-heritage.com to get additional information on our services and resources.

Tags: COVID-19, #homehealth, Coronavirus