Due to the COVID-19 Public Health Emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) has waived the Home Health Condition of Participation under 42 CFR § 484.55(a) regarding the initial assessment: This change allows home health agencies to perform initial assessments and determine patients’ homebound status remotely or by record review.

However, it is important to note that the initial assessment visit is different from the Start of Care comprehensive assessment visit – even though both are typically done at the first visit in the home.
The initial assessment visit is required to determine the patient’s immediate care and support needs, and the patient’s eligibility for coverage under the Medicare home health benefit:

  1. Is the patient homebound?
  2. Is the patient under the care of a physician?
  3. Is the patient in need of skilled services?
  4. Has the patient had a face-to-face encounter with a medical provider as mandated by the Affordable Care Act?

The initial assessment visit must be done within 48 hours of the patient’s referral to home care or return home from the inpatient facility, or on the physician-ordered start of care date. This waiver for the COVID-19 PHE allows the agency to carry out the initial assessment via phone call to the patient or by medical record review instead of making an actual in-person to the patient’s home. This determination must still be completed within the 48 hours following referral or return home but does not require a home visit within that time period.

The Start of Care (SOC) comprehensive assessment is the required in-person clinical assessment of the patient’s physical, functional, mental, psychosocial, and cognitive status to identify the needs of the patient and caregiver that will be addressed by the home health agency’s services. This comprehensive assessment at SOC includes the collection of OASIS data. This comprehensive assessment must be completed within a specific time frame after the SOC date (first reimbursable visit). Prior to the COVID-19 PHE, agencies had a 5-day window to complete data collection for the SOC comprehensive assessment – under the COVID-19 PHE changes, that time frame has been extended to 30 days following the SOC date.

Most of the time, the agency sends the clinician (nurse, PT or SLP) to “admit the patient” – the clinician evaluates the patient to make sure they meet the requirements for home care services, explains and signs the consents, and proceeds with the patient assessment and drug regimen review – all at the same visit. Key point: the initial assessment and the comprehensive assessment are two separate requirements under the CoPs.

The waiver under the COVID-19 PHE applies only to the initial assessment – the initial assessment may be done remotely by phone or by reviewing the medical record, but the SOC comprehensive assessment still requires an in-person visit to the patient.

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