Tuesday 18 October 2016

Home Health Agencies (HHAs)

Home Health Agencies (HHAs)


A. General Background Information
An HHA is an entity that provides skilled nursing services and at least one of the following therapeutic services: speech therapy, physical therapy, occupational therapy, home health aide services, and medical social services. The services must be furnished in a place of residence used as the patient’s home.

Like most certified providers, HHAs receive a State survey (or a survey from an approved accrediting organization to determine compliance with Federal, State, and local laws), and must sign a provider agreement. All HHA services, moreover, must be part of a plan of care established by a physician, accompanied by a certification from the physician that the patient needs home health services. HHA services can be covered even if the patient lives with someone who might ordinarily be able to perform such services himself/herself.

B. Capitalization and Site Visit Requirements
See section 15.26.2 of this chapter for more information on HHA capitalization requirements. See sections 15.19.2 through 15.19.2.5 for more information on HHA site visit requirements.

C. HHA Components
There are three potential “components” of an HHA organization:
Parent – The parent HHA is the entity that maintains overall administrative control of its location(s).
Sub-unit – A sub-unit is associated with the parent HHA but services a different geographic area. It is thus considered a semi-autonomous HHA, since it is too far away from the parent HHA to share administration/supervision on a day-to-day basis. This means that HHA sub-units must separately enroll in Medicare, obtain a separate State survey, and sign a separate provider agreement. As with parent HHAs, sub-units receive their own 6-digit CMS Certification Number (CCN).

Branch – A branch is a location or site that services patients in the same geographic area as the parent and shares administration with the parent on a daily basis. Consequently, unlike sub-units, branches need not enroll separately. They can be listed as practice locations on the main provider’s (or sub-unit’s) Form CMS-855A. Though the branch receives a 10-digit CCN identifier, it bills under the parent HHA’s or sub-unit’s CCN number.

The question of whether a particular location qualifies as a branch or a sub-unit – which will determine whether a separate Form CMS-855A enrollment is needed – is resolved by the RO.
Consider the following scenario:

PARENT HHA
owns owns owns
BRANCH A SUB-UNIT B BRANCH C
operates
BRANCH D


Here, the parent HHA has two branches (A and C) and one sub-unit (B). B also has a branch (D).

They will be enrolled as follows:• The parent HHA must complete a Form CMS-855A, undergo a State survey, and sign a provider agreement.
• Branches A and C must be listed as practice locations on the parent’s Form CMS-855A because a branch is sufficiently “attached” to the parent to be considered part of it.
• Sub-unit B must: (1) enroll separately from the parent, (2) complete its own Form CMS-855A, (3) undergo its own survey, and (4) sign its own provider agreement. For enrollment purposes, it is considered a separate and distinct entity from the parent, hence requiring a separate enrollment. (This also means that Sub-unit B would not have to be listed on the parent’s Form CMS-855A as a practice location.)
• Because sub-units, like parents, can have branches, Branch D would be listed as a practice location on Sub-unit B’s application.
See Pub. 100-07, chapter 2, section 2182, for more information on branches.

D. Out-of-State HHA Branches 
In general, an HHA can only have a branch in another State (and treat it as a branch, rather than a separate HHA) if there is a reciprocity agreement between the two States. If none exists, the out-of-state location must enroll as a new provider by submitting a new Form CMS-855A and signing a separate provider agreement. It cannot be treated as a branch/practice location of the main HHA. (See Pub. 100-07, chapter 2, section 2184 for specific provisions regarding HHAs that cross State lines.)

E. Additional Data
For more information on HHAs, refer to:
• Sections 1861(o) and 1891 of the Social Security Act
• 42 CFR Part 484
• 42 CFR § 489.28 (capitalization)
• Pub. 100-07, chapter 2, sections 2180 – 2198C (State Operations Manual)
• Pub. 100-04, chapter 10 (Claims Processing Manual)
• Pub. 100-02, chapter 7 (Benefit Policy Manual)

No comments:

Post a Comment

Popular Posts