A Resumption of Care (ROC) assessment is required any time the patient is admitted as an inpatient for 24 hours or more for other than diagnostic tests and returns to home care. A ROC must follow a transfer if the patient returns to the agency within the episode.

However, as you’d probably expect in healthcare, the guidelines aren’t quite that simple. Let’s talk about some of the finer points of resumption of care guidelines for home health.

The CoPs state at 42 CFR 484.55 that the ROC assessment is required: Within 48 hours of the patient’s return to the home from a hospital admission of 24 hours or more for any reason other than diagnostic tests, or on physician-ordered resumption date. The OASIS Q & A Q15.1.1 adds that the agency must complete the ROC “within 48 hours of knowledge of discharge…”

Let’s look at each of these situations to better understand the resumption of care requirements:

The first situation is when the agency is aware that the patient was admitted to the inpatient facility and knows when the patient will be discharged. In this case, the ROC assessment is to be completed within 48 hours of discharge from the facility. This is the ideal situation for compliance, as the ROC can be scheduled for completion well within the timeline of the patient’s discharge from inpatient care.

The second situation is when the physician has provided a specific date for ROC. In that case the order for the ROC will indicate the date for the visit. The indicated date may be before the 48 hours or after the 48 hours. For example, insulin injections have been ordered for the patient with exacerbated diabetes and care needs to resume by the next scheduled injection, or orders for wound care will not commence until the surgeon removes the first dressing in 3 days.

Note: An order for a ROC visit to be provided outside the 48-hour timeframe must be received prior to the end of the 48 hours.

The third situation is when the patient is admitted and discharged from an inpatient facility without the agency’s knowledge. The first visit made by anyone from the agency is M0032. That first visit is usually when the agency finds out that the patient had a qualifying admission. The agency then has 48 hours from knowledge of inpatient discharge, to complete the ROC assessment. M0032 (Date of ROC) should be the first visit by anyone from the agency, including home health aides and other disciplines. The agency then has 48 hours to complete the ROC assessment. M0090 is the date of the actual assessment by the qualified clinician.

We hope this guide has cleared up some of the idiosyncrasies of resumption of care and how home health agencies must work to be compliant with them. 

OASIS Category 4 Q23.9 and Category 3 Q 11.1.2

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