Certifying COVID-19 patients

CMS has broadened home health eligibility to handle COVID-19 patients

Patients must meet strict homebound criteria to receive treatment and services from home care providers under normal circumstances, but the COVID-19 public health emergency has changed the rules.

Earlier this week, the Centers for Medicare and Medicaid Services (CMS) announced sweeping temporary regulatory changes to help home care providers meet an anticipated influx of COVID-19 patients over the next few weeks as hospitals fill and health officials try to mitigate spread by keeping those who are ill in their homes.

Among those changes are new eligibility criteria including patients with COVID-19 among those who can receive Medicare-reimbursed services in the home, and more lenient rules about who can determine whether a patient meets the criteria.

Home health will also be able to test patients in their homes for COVID-19.

Changes in who can certify

Previously, CMS required only physicians as described under the Social Security Act to certify homebound patients and sign off on the plan of care. Now, under the Coronavirus Aid, Relief and Economic Security (CARES) Act signed into law last Friday, three additional types of providers will be allowed to certify patients for home care, issue orders and sign the plan of care.

Nurse practitioners, clinical nurse specialists and physician assistants already had approval from CMS to perform the crucial face-to-face encounter between physician and patient which is required for eligibility. But in almost every state, a physician had to take it from there, signing that he or she accepted the other provider’s clinical encounter with the patient as valid and issuing all the orders for treatment and services.

“CMS has said it will not be auditing documentation for episodes of care during the COVID-19 crisis to make sure that a physician issued the orders and signed the plan of care,” said J’non Griffin, owner and president of Home Health Solutions, a nationwide consulting and outsourcing firm for home health, hospice and long-term care.

Check with your state

Because states have different standards, accrediting body CHAP, the Community Health Accrediting Partner, is recommending in its fact sheet on the home health waivers that agencies check state licensure law to make certain they can accept orders from nurse practitioners, clinical nurse specialists or physician assistants .

Patients with COVID-19

Home health agencies will be able to provide treatment and services for patients who have a diagnosis of COVID-19 or are suspected of having COVID-19, according to the blanket waiver issued by CMS.

The physician or other allowed provider type will need to document that the patient should not leave his or her home, explaining the risk and the need for skilled services.

New eligibility requirements also grant homebound status to patients whose underlying medical conditions place them at increased risk of COVID-19 when leaving home.

New telehealth requirements

In some cases, agencies may be able to use telehealth to secure the face-to-face encounter required for home health certification or to perform the initial assessment of the patient. CMS has relaxed its telehealth rules to limit exposure and expedite timely services to patients. See our blog post on telehealth here.

COVID-19 testing

Home health agencies will be able to perform diagnostic testing for COVID-19 in the homes of patients. A home health nurse may obtain the sample for COVID-19 diagnostic testing during an otherwise covered visit of a Medicare home health patient already receiving Medicare home health services. The sample will be tested in a laboratory COVID-19.