No payments can be made by Medicare to a home health care agency for care provided to a client unless a Plan of Care (CMS document 485) for that client was previously submitted. Furthermore, this Centers for Medicare and Medicaid Services (CMS) form must be completed every 60 days for each client receiving home care services. Therefore, developing a project management strategy for your home health care staff is imperative in order to ensure that Medicare will reimburse your agency located in Illinois (or elsewhere in the US) for the care provided to your clients.
The following describes some key parts of the Plan of Care form (CMS document 485) for use in training your new nursing staff. A consultation with professionals at Liberty Consulting and Management Services in Illinois can assist you with health care accounting and billing services, as well as enable you to better understand all parts of the Plan of Care form.
What are Frequently Asked Questions (FAQs) about the CMS Plan of Care form?
A memorandum of the DHHS’ Center for Clinical Standards and Quality on January 23, 2019 alluded to changes in 2018 to the Home Health Agency Conditions of Participation (CoP) that necessitated documenting answers to Frequently Asked Questions (FAQs) about CoP changes.
Meanwhile, a federal regulation (42 CFR Section 484.55) requires home health care agencies to conduct an assessment for each home health care client at the time of initial home health care assessment visit and upon completion of the comprehensive assessment.
One of the most important answers listed in the aforementioned memorandum of FAQs is that –for Medicare to pay a specific invoice from a home health care agency – a physician’s verbal and/or written order for home health care needs to occur before any home health care services are provided. Moreover, mid-level clinicians (such as nurse practitioners and physician assistants) cannot write orders for home health care services instead of a physician.
Notably, the client’s comprehensive assessment – at (or before) five days after the documented Start of Care (SoC) date on the Plan of Care form – must be completed for Medicare to pay for any home health care services provided to that client.
Why a Project Management Database is Useful
Developing a viewable checklist within a project management database is one way to enable home health care billing staff to alert nursing staff that a client’s initial assessment or comprehensive assessment is due within 48 hours. In turn, this can aid you in determining your weekly nursing staff (and other clinical staff) scheduling needs.
The CMS also requires that the Plan of Care form for each client include the given client’s risk for Emergency Department (ED) visits and hospitalization (in tandem with the intervention that the home health care agency will utilize to address each listed risk factor).
A project management database may include a section on risk factors that can alert billing staff if planned interventions were not noted by nursing staff (corresponding to a client’s documented risk factors). Then, that billing staff member can alert the nursing staff manager that this missing information needs to be added before submission of the Plan of Care form.
Through incorporation of the items within the Plan of Care form within an overall project management strategy, the billing staff member checking the database on a regularly-scheduled basis can notify the appropriate nursing staff member to complete the missing information before the Plan of Care is submitted to the CMS. In this way, submission of a premature invoice to the CMS may be avoided.
Documenting Functional Limitations on the Plan of Care (CMS document 485)
Among the nine numbered “check-box” options on the Plan of Care form for Section 18.A (Functional Limitations) are the following:
- Bowel/Bladder (Incontinence);
These functional limitations may impact the type of home health care visits allowed by Medicare, so a process for double-checking correct documentation on the Plan of Care form is a good idea. If you are opening a new home health agency in Illinois (or elsewhere in the US), developing a written protocol for training nursing staff at your home health care agency in properly completing the Plan of Care form is advisable.
You can schedule a consultation with Illinois’ Liberty Consulting and Management Services to learn more about training your nursing staff in the proper completion of the current CMS Plan of Care form, as well as to train your home health care billing and accounting staff in current Medicare billing processes.