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Volume 20.02

The U.S. Centers for Medicare & Medicaid Services (“CMS”) has provided Notice on February 24, 2020 regarding the updated Home Health Agency Cost Report (“CMS-1728-19”).  Additionally, the forms and instructions are available here.  The updated cost report is effective for cost reporting periods beginning on or after July 1, 2019 and ending on or after Jun 30, 2020.

Notable changes include, but are not limited to:

  • Reporting of LPN visits and patients served,
  • Reporting of PT assistant visits and patients served,
  • Reporting of OCTA visits and patients served,
  • Calculation and reporting of average hourly wage rates (salaries and benefits) for patient care personnel (W-2 employees and contracted personnel),
  • New cost centers (costs must be accumulated and reported where applicable) for:
    • Nursing Administration,
    • Medical Records,
    • Remote Patient Monitoring,
    • Telehealth,
    • Advertising,
    • Fundraising,
    • Skilled Nursing Care – LPNs,
    • PT Assistants, and
    • COTA.

We receive many questions regarding the difference between “Remote Patient Monitoring” and “Telehealth”.  We will be separately reporting on these activities in an upcoming release.

The new general service cost centers require allocation to patient service and non-reimbursable cost centers as follows:

  • Nursing Administration – nursing care (patient care hours),
  • Medical Records – time spent by discipline and other activities, and
  • Remote Patient Monitoring – time spent by discipline and other activities.

CMS’s responses to the comments on the original draft cost report have not been released as of the date of this alert.  The Health Group, LLC is anxiously awaiting the comments and responses.  The revised cost report will pose significant reporting issues for home health agencies.  As we further review the proposed changes, more information will be provided on the changes as well as guidance on preparing the revised cost report.

Comments will be accepted on or before March 25, 2020 and The Health Group, LLC will be submitting comments.  If you would like a copy of our comments, make your request to contact@healthgroup.com.