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Home Health LineRegulatory news, benchmarks and best practices
to build profitable home care agencies
homehealthline.com
July 7, 2014 | Vol. 39, Issue 26
Benchmark of the Week
CMS will release new OASIS-C1 guidance
manual any day. Are you ready?
 CMS is moving full speed ahead with OASIS-
C1, effective Jan. 1. Make sure you are ready
by signing up for the 10th Annual National
Quality Outcomes OASIS-C Conference
Sept. 15 to 18 in Chicago. Save $300 by
signing up by July 7 at
www.homecareoutcomesconference.com.
Opposition mounting against Part D plans’ role
in deciding hospice drug coverage.............................1
CMS’ provider relations coordinator to
help agencies with contractors..................................1
Require clinicians to turn in same-day
documentation to avoid deficiencies..........................2
Use objective measurements to document
required therapy reassessment visits........................3
Make it essential for staff to submit
documentation in a timely fashion..............................4
Learn from the past, prepare for the
future with revised timelines......................................4
Most common referral sources for home
health agencies...........................................................5
Having same nurses, aides visit ALFs each
time will strengthen relationships..............................6
Proposed PPS rule would trim payments, ease
face-to-face burden....................................................8
Hospice compliance
Opposition mounting against Part D plans’
role in deciding hospice drug coverage
The hospice industry now has nearly four dozen organiza-
tions — including the Medicare Payment Advisory Commission,
AARP and the American Medical Association, the National
Association for Home Care and Hospice and the National
Hospice and Palliative Care Organization — joined in opposi-
tion to CMS instructions which would require that Part D drug
plans preauthorize drugs needed by hospice patients.
(see Part D, p. 7)
Denials management
CMS’ provider relations coordinator to
help agencies with contractors
You now have a new CMS resource to turn to when you expe-
rience problems with recovery audit contractors (RACs) and
other contractors.
The new staff position, which CMS announced last month,
is designed to “increase program transparency and offer more
efficient resolutions to providers affected by the medical review
process,” CMS says. The provider relations coordinator will
“improve communication between providers and CMS.”
(see Coordinator, p. 8)

July 7, 2014 Home Health Line
Exclusive web content and searchable CMS documents at www.homehealthline.com.2
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CMS survey penalties
Require clinicians to turn in same-day
documentation to avoid deficiencies
Have clinicians complete their electronic clinical
documentation during or right after each visit. That step
can protect you from ramped up state surveyor scrutiny
on documentation timeliness.
In the past two months, two home health agencies
in CMS Region 9 received multiple condition-level
deficiencies, including G236 (failed to maintain
client clinical records that met accepted professional
standards) and G123 (Organization, services furnished,
administrative control and lines of authority for the
delegation of responsibility down to the patient care
level are clearly set forth in writing and are readily
identifiable), says Michael McGowan, senior consultant/
expert witness at Medicare Appeals Development, based
in Albuquerque, N.M.
Region 9 includes Nevada, American Somoa,
Arizona, California, Guam, Hawaii and the Northern
Mariana Islands.
Agencies in both cases were using electronic medical
record (EMR) systems and had policies that required
clinical documentation to be turned in within a week, a
policy not acceptable or sufficient to meet professional
standards to surveyors because a patient who was
declining could be in jeopardy without the agency
knowing it, McGowan says.
That’s a warning to all agencies as state surveyors
recently gained the authority to hand out civil monetary
penalties for as much as thousands of dollars a day for
repeat standard- and condition-level deficiencies.
The push to adopt EMRs in all areas of health care
has led to an increased expectation from state surveyors
that home health agencies should be using these systems
as designed in terms of completing documentation
during or directly following the visit, says McGowan.
Doing so ultimately leads to better care coordination
with colleagues and clinical supervisors.
In its plan of correction, one of the agencies
McGowan advised must now adhere to a policy of having
clinicians turn in clinical documentation within 72 hours
or potentially be terminated from Medicare pending an
appeal to an Administrative Law Judge, he says. Still, he
suggests documentation should be done the same day.
Paper documentation needs to be timely
Agencies that are still on paper should follow the
same advice and turn in documentation on the same day
in order to adhere to the same professional standards
required in Medicare’s Conditions of Participation and by
state nursing licensing boards, says McGowan.
At Sutter Care at Home, a not-for-profit home care and
hospice agency based in Emeryville, Calif. with branches
in 24 counties in northern California, leadership
recently approved a written company policy that the
agency’s roughly 1,000 clinicians must submit clinical

Home Health Line July 7, 2014
© 2014 DecisionHealth®
| www.decisionhealth.com | 1-855-CALL-DH1 3
documentation via mobile tablets to the agency’s EMR,
Dallas-based Homecare Homebase, within 24 hours.
This policy excludes one rural branch that is still on
paper and whose clinicians have to drive long distances
to treat patients, says Sandy Sanville, director of clinical
practice for Sutter Care at Home.
Those clinicians must turn in their documentation
within 48 hours, says Paula Suter, director of clinical care
management for the Sutter Center of Integrated Care,
Sutter Care at Home.
Tips for timely documentation
•• Work out a comfortable routine for
completing documentation. Have clinicians use their
cars as a makeshift office to complete documentation
for about 10 to 15 minutes after each visit and before
they go to their next visit, says McGowan. Alternatively,
have them go to a park, library or favorite coffee shop
mid-day to complete documentation on morning
patients, and do the same in the afternoon, he says. The
idea is that they should not go home without completing
that day’s documentation.
•• Show clinicians how timely documentation
can improve their quality of life. One clinician at
Sutter Care at Home was not comfortable using mobile
tablets and resisted charting in the home, says Sanville.
Her supervisors asked her to use the point-of-care device
during the visit after she received more training, she says.
Once the employee began to document in the home, she
realized it made her life more efficient.
•• Use EMRs as a tool to train clinicians on
documentation. Many EMR systems allow quality
improvement staff and clinical supervisors to determine
how much time was spent on documentation and how
much time was spent on submission, says Sanville.
Quality managers can use this feature to train clinicians
in a more targeted way. — Nicholas Stern (nstern@
decisionhealth.com)
Therapy reassessments
Use objective measurements to document
required therapy reassessment visits
Reduce your risk for costly denials associated with
the therapy reassessment requirement by conducting
tests like the 30-second chair stand test.
Tests such as these have been proven to reduce
agencies’ average per-record risk by $672, according to a
study by Northampton, Mass.-based Fazzi Associates that
looked at more than 3,000 therapy reassessment records
from over 60 agencies between August 2011 and June
2012. The content of the reassessments, including proper
documentation to support the services, was one of the
largest issues agencies had prior to receiving education
on the topic.
The chair stand test is one example of a way to objec-
tively measure lower extremity weakness by comparing
how many times a patient can stand from a chair within
30-seconds with normative data based on age and gender,
says Dr. Kenneth Miller, physical therapists and clinical
educator at Catholic Home Care in Farmingdale, N.Y.
Provide training, annual follow-up
Quality managers should perform onsite visits with
the therapists to watch how they conduct the functional
testing, Miller says.
They should also track individual therapists’ perfor-
mance on the reassessment requirements on at least a
quarterly basis, says Miller.
Incorporating education, performance tracking and
auditing have resulted in greater compliance rated and
reduced risk of denials, he says.
Many electronic medical records (EMR) systems have
built in queries that quality or compliance staff can use
to audit for cases that receive visits beyond the 13th and
19th reassessment in order to mitigate risk by improving
compliance, Miller says.
Those therapists who are having trouble with this
requirement can then receive follow-up instruction.
Conduct reassessments bi-monthly
Don’t forget to include the basics of when to conduct
therapy reassessments in your training.
Reliable Healthcare Solutions in Morgantown, W. Va.,
has accomplished 100% compliance with the therapy
reassessment regulations. That’s a big improvement
from between 10 and 12 instances of noncompliance
the agency had a few months ago, says Dale Derby,
home health director who is also responsible for quality
management at the agency.
Therapists were failing to complete reassessments
at the right time — on the 13th and 19th visit or every
30 days for single-therapy cases, says Derby. For

multi-discipline cases, therapists have to complete
reassessments on visits 11, 12 or 13 to meet the 13th visit
requirement and on visits 17, 18 or 19 to meet the 19th
visit requirement.
Solution: The agency began tracking compliance and
discussing the matter at weekly operations meetings,
Derby says.
He also began training clinicians in two-on-one
sessions for a couple hours each session over a period of
about a month on the Medicare regulations concerning
therapy services, including information about whether
the patient’s condition is still appropriate for therapy
services over the course of a care episode, he says.
He developed the training materials by distilling infor-
mation from a variety of sources such as the Medicare
administrative contractor, CGS Administrators, Medi-
care’s Conditions of Participation and more, he says.
Sections 40.2.1 (b) of Chapter 7 of the CMS Home
Health Manual, for instance, is particularly helpful to
understanding reassessment timing.
Therapists should conduct reassessments every two
weeks; this will ensure the therapist meets the Medicare
requirement that a reassessment be completed at least
every 30 days and gives the patient the best possible
treatment, Miller recommends. — Nicholas Stern
(nstern@decisionhealth.com)
Editor’s note: The proposed 2015 PPS rule, released
July 1, would change therapy reassessment timeframes.
Therapy reassessments would occur every 14 calendar
days rather than before the 14th and 20th visits and once
every 30 calendar days. See upcoming issues of HHL for
more details.
ICD-10 delay
Learn from the past, prepare for the
future with revised timelines
Now is the time to go back to your ICD-10 transi-
tion team and do a post-mortem of all your preparation
efforts to assess what your agency was able to accom-
plish, what it has yet to achieve, where your training was
effective and what areas you may have neglected.
Since ICD-10 was delayed to Oct. 1, 2015, determin-
ing the most effective approach to ongoing preparation
efforts over the next year and a half will depend on your
agency’s level of preparedness at the time of the delay,
says Trish Twombly, senior director for DecisionHealth in
Gaithersburg, Md.
For example, those agencies that were diligently
preparing and following recommended timelines that
called for the dual coding of 10 charts a week by April
2014, should scale back their dual coding efforts, but
Make it essential for staff to submit documentation in a timely fashion
Agencies that have issues with timely documentation need to incorporate that requirement into their
conditions of employment.
Make sure your agency has a clear, written policy regarding expectations for clinicians to complete
documentation and upload it to the EMR system. Failure to do so should result in disciplinary actions, advises
Robert Markette of Hall, Render, Killian, Heath Lyman in Indianapolis.
Likewise, warnings for violations of the policy should be handed out in written notices. This could help prove
that the agency was not being subjective or picking on anyone for violating the policy should a clinician decide to
file a complaint with the Equal Employment Opportunity Commission (EEOC).
A third warning in such a policy, for example, could mean termination for the errant employee.
Aside from the requirement that clinicians using an EMR turn their in documentation within 24 hours, Sutter
Care at Home’s standard also requires all visit documentation except for the comprehensive start of care visit be
completed or close to completion during the actual visit while in the home, says Sandy Sanville, director of clini-
cal practice for Sutter Care at Home.
Clinicians at Sutter Care at Home receive a yearly supervisory visit during which a manager observes them
documenting in a patient’s home. Supervisors also monitor documentation timeliness on an ongoing basis
through the EMR, Sanville says. This is also a focus during new clinician orientation. — Nicholas Stern (nstern@
decisionhealth.com)

not stop them completely, Twombly says. Instead of dual
coding 10 charts a week, now maybe just do two.
It’s important to see that all the time, effort and
money that’s been invested in ICD-10 to this point isn’t
wasted, she says.
The U.S. Department of Health and Human Services
is expected to release an interim final rule “in the
near future” enacting Oct. 1, 2015, as the new ICD-10
compliance date, and requiring all HIPAA covered
entities to use the ICD-9 system through Sept. 30, 2015,
CMS said its statement released May 1.
Coders resolute to keep training
More than 50% of home health agencies surveyed
about the ICD-10 delay said while they could have been
ready, they’re appreciative of more time to prepare. But
35% said they were prepared and are disappointed by
the abrupt decision, according to the results of Decision-
Health’s ICD-10 Delay Survey of 208 home health agencies.
Despite the different feelings about the delay, every
coder contacted by DecisionHealth expressed deter-
mination to keep training and preparing, a position
affirmed by coding experts.
Assess gaps reset training timeline
Reset your ICD-10 training timelines to one year from
now, and if you haven’t been working from a timeline,
now’s the time to get on one, says Ann Rambusch, presi-
dent of Rambusch3 Consulting in Georgetown, Texas.
A timeline developed for implementation this year
called for establishing a transition team, budget and
implementation plan by the end of the 2013 summer.
Work from those benchmarks and begin retooling
those things to be put into place over the next year, paying
particular attention at this point to your budget and to
critical gaps in your training processes, says Twombly.
Quality and clinical managers who have already
conducted documentation and/or coding audits to see
whether clinicians are prepared for the increased level
of detail required by ICD-10 should use the delay to do
so again, this time with the benefit of their increased
knowledge of ICD-10, says Twombly.
Make a list of your agency’s top 10 diagnoses and make
sure the clinical documentation is adequate for what will
be required in ICD-10, she says. For example, make sure
clinicians treating patients with diabetes with kidney
failure document the stage of kidney failure, which is a
requirement in ICD-10.
Based on the results of clinician audits, quality manag-
ers can focus training individual clinicians on such
requirements as needed, Twombly says.
Also, many agencies have overlooked the
importance of training their intake staff in the increased
documentation demands of ICD-10, Twombly says.
However, it’s these people who are in a position to
ensure that critical information about patients’ diagnoses,
required to properly code in ICD-10, is received from
referral sources up front, she says.
To combat this training gap, make a list of the top 20
diagnoses that your agency treats, such as congestive
heart failure (CHF) and chronic obstructive pulmonary
disease (COPD), and then create tools that can be given to
intake staff to help alert them to when they will need more
specifics about a diagnosis, Twombly says.
Currently, coders should focus on mastering or
maintaining knowledge of ICD-10 fundamentals, like the
Most common referral sources for
home health agencies
Below is the list of the most common home
health referral sources. Note that nearly 20% of
respondents to a recent HHL survey said that
assisted living facilities were a top referral source.
(See related story, p. 6.) The data include 50 home
health agency responses to a recent HHL survey.
0%
10%
20%
30%
40%
50%
60%
70%
80%
Physicians(general)Hospitals
SkilledNursingFacilities
Physicians(specialists)
AcuteCareRehabilitation
AssistedLivingFacilities(ALFs)
WoundCareCenters
InpatientRehabilitation
PrviateDutyCompanies
Other
ACOsorOtherCare
TransitionProjects
Top referral sources
Percentage of responents

guidelines and conventions, with the aim of completing
that by December. Intensive training should begin in
January 2015 and continue through April, at which point
dual coding should commence, says Judy Adams, presi-
dent of Adams Home Care Consulting in Asheville, N.C.
— Megan Gustafson (mgustafson@decisionhealth.com)
Marketing referrals
Having same nurses, aides visit ALFs
each time will strengthen relationships
Assign the same group of employees to visit assisted
living facilities (ALFs) each time you have appoint-
ments there. The assurance that the same people from
your agency will visit each time will make patients and
employees more comfortable about letting your agency
into the facility, and could generate more referrals.
Comfort Home Health in Daleville, Ind., assigns a
physical therapist, occupational therapist, nurse and
aide to a specific ALF.
The familiarity the agency creates with ALFs — and
the promises it keeps — helps it receive about 20% of its
roughly 40 referrals a month through ALFs, says Kathy
Eichelman, the agency’s community liaison.
Strong relationships with ALFs will generate refer-
rals, as many residents within the facilities have medi-
cal issues that qualify them to become Medicare home
health patients.
ALFs are the sixth most common referral source in
home health, according to HHL’s 2014 referrals survey.
(See benchmark, p. 5.) About 18% of the survey’s 52
respondents listed ALFs among their agency’s top over-
all referral sources.
Show you can keep patients at home
Your agency also can stand out to ALFs by showing
that you can help with their bottom lines by keeping
their occupancy rates high, industry experts say.
Bring outcomes data to a meeting with the ALF,
advises Katherine Northcutt, Marietta, Ga.-based senior
manager at Simione Healthcare Consultants.
Display your rehospitalization rates overall and by
disease category, and show how they compare with
other area agencies (HHL 6/30/14).
When first speaking with an ALF’s employees, ask
about the facility’s process for referring a patient to
home health. If its social services director serves in that
role, she would be the person to speak with about devel-
oping a relationship, Northcutt says.
Your goal from the initial conversation should be to
determine the ALF’s needs and address how your agency
can lessen problems, Northcutt recommends. Among the
questions to ask: What are the biggest challenges with
keeping residents? How is the ALF able to meet residents’
needs when they return from a hospital stay? How often
are people hospitalized? Are there a lot of fall issues?
After an initial conversation, provide the facility with the
data that shows your agency can help best, Northcutt says.
Offer educational sessions in ALFs
Spending time inside an ALF and offering free,
10-minute monthly wellness presentations to residents
also could potentially be a good way to generate refer-
rals, adds Lori Moshier, president of Novi, Mich.-based
Novaetus, a marketing firm.
Presentation topics could include elder abuse, how to
avoid falls in your home and heart-healthy diets for seniors.
Since you’re not offering anything of value — much
of the information you’d provide is available free online
— there would not be a kickback concern, says home
health attorney Robert Markette of Hall, Render, Killian,
Heath Lyman in Indianapolis.
But agencies performing presentations for residents
should not spend more than $10 per person each time on
food, Markette advises. And agencies should not spend
more than $50 per person on food over the course of a year.
Sell your agency’s benefits to ALFs
•• Explain that you want to work with them, not
against them. Educate ALFs about how your agency is
trying to help their residents stay healthy and at home,
says Jessica Vaughn, marketing and admissions director
for At Home Assisted Living Services, an Anderson, Ind.-
based private duty agency.
In the past 18 months, 16 to 18% of the agency’s refer-
rals have come from ALFs. The agency receives about
200 referrals a year.
•• Highlight things you can do that the ALF
can’t. At Home Assisted Living Services has some clients
living within ALFs who simply need someone to spend
the night and ensure they’re safe, Vaughn says. An ALF
employee wouldn’t be able to spend all night with a
resident, she says.

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•• Tell them you’ll respect their protocols and
make them feel comfortable. Say that your employees
will sign in at the ALF’s front desk and park in appropri-
ate parking spaces, Moshier says.
Also, if possible discuss your consistency in sending
the same group of caregivers to the ALF for visits. “That
goes a long way with those types of professionals,
because they want to know who’s coming in and
out of their building,” Vaughn says. — Josh Poltilove
(jpoltilove@decisionhealth.com)
Part D
(continued from p. 1)
In a letter to CMS last week, the organizations have
urged CMS to withdraw its instructions “until a workable
alternative is developed that does not place the burden
of resolving payment disputes squarely on the shoulders
of terminally ill Medicare beneficiaries.”
The guidance in question — which took effect May 1
— states that hospices must provide “a coherent clinical
explanation” to the patient’s Part D plan about why the
drug is medically necessary but unrelated to a patient’s
terminal condition and therefore not a cost the hospice
needs to cover (HHL 5/12/14). Without such an explana-
tion, the plan need not pay.
Plan decisions against drug coverage have faced
VNA of Hudson Valley’s hospice unit with hard choices.
Recent examples cited by Rose Rosenberg, the Tarry-
town, N.Y., agency’s VP for hospice, include two terminal
cancer patients in need of an anticoagulant for their
deep vein thrombosis. The patients’ Part D plan wouldn’t
pay the twice-daily cost of $180.
Those patients, both homebound, were able to
choose palliative care as home health patients as an
alternative to hospice. But, more and more the hospice
unit finds itself, for compassionate reasons, absorbing
the cost of secondary diagnosis drugs needed by non-
homebound patients who can’t afford to foot the bill
themselves, Rosenberg relates.
Authorization stems from OIG report
The issue of coordinating payments for drugs
required by hospice patients grew out of an HHS Office
of Inspector General study that found that Medicare had
to spend $400 million in 2012 for drugs used by hospice
patients but not covered by the hospice program.
CMS has indicated that it ultimately would turn over
to an independent reviewer the task of deciding whether
disputed drug costs belong to the hospice or to the
patient’s drug plan. But that process won’t be available
in 2014 and first must be established through regulation,
presumably in the final 2015 hospice rule.
Meantime, the potential harshness of CMS’ current
directions is evident in letters many hospices have
received from a debt collection agency acting in
behalf of Part D carrier United Healthcare Insurance.
Sent by debt collector Payment Resolution Services
of Nashville, Tenn., the letters seek reimbursement for
pain-relieving analgesics billed in 2011 and 2012, which

according to the collection company actually were costs
the hospices were responsible for.
In one case known to HHL, the Payment Resolution
Services is seeking $1,000; in the second, the amount
demanded is about $20,000, which the hospices in ques-
tions have 30 days to pay, the letters state. Hospices are
being told they have 30 days from the receipt of the letter
to dispute the debt.
CMS advised Part D drug plan sponsors last October
of their obligation to recoup the payments in question
(HHL 6/16/14). — Burt Schorr (burt.schorr@verizon.net)
Coordinator
(continued from p. 1)
The coordinator will listen to overall process
concerns and suggestions, though agencies still should
direct questions about specific claims to RACs and
Medicare Administrative Contractors (MACs), CMS says.
Latesha Walker, the new CMS coordinator, has
previously served as a program relations manager
and senior advisor with CMS. She is helpful, and if she
doesn’t know answers to questions, she finds people
who do, says consultant Wayne van Halem, president
of Atlanta-based van Halem Group. Van Halem has
worked with Walker in recent weeks when dealing with
issues involving StrategicHealthSolutions, a Supplemental
Medical Review Contractor (SMRC) that he believed was
neither cooperative nor communicative.
But it’s unclear how effective this position will be.
Given the volume of work RACs and MACs perform,
Walker likely will be “hammered” with calls and emails in
the new position, argues attorney Robert Markette of Hall,
Render, Killian, Heath Lyman in Indianapolis.
RAC pause continues for agencies
Walker’s position will be even busier after RACs begin
issuing additional documentation requests (ADRs) again
in the coming months.
On Feb. 18, CMS announced that it told RACs to stop
issuing ADRs until it awards the next round of contracts
(HHL 3/3/14). It appears contracts will be awarded this
summer, followed by post-award protests that will further
delay the start date for the new RACs, says Emily Evans,
a partner and legislative/regulatory analyst for Nashville-
based Obsidian Research Group.
In the meantime, CGI Federal Inc. elevated its pre-
award bid protest over re-procurement of the RAC
contracts to the Court of Federal Claims last month. CGI
is currently the RAC for Region B, which includes Ohio,
Michigan and five other states.
The lawsuit seeks an injunction against the award
of the new RAC contracts. It also asks the federal court
to eliminate new payment terms prohibiting RACs
from being compensated until after the second level of
appeal — a payment delay preventing RACs from being
paid for about a year, Evans says.
The lawsuit is likely among the reasons CMS is
delaying the contracts for all RAC regions, including the
region that will handle claims nationwide for more than
12,000 home health agencies, as well as hospices and
DME companies, she says.
When to contact the CMS coordinator
•• Notify the contractor of lack of timely review
results. Delays on notice letters from RACs create
problems for some agencies, Markette says. RACs
communicate to MACs electronically, but send the
notice to the provider by regular mail.
•• Point out cases where the contactors’
interpretation of the law is questionable. Situations
arise where contractors view certain records with
basically the same wording and approve some while
denying others, says Arlene Maxim, owner of A.D.
Maxim Consulting in Troy, Mich. — Josh Poltilove
(jpoltilove@decisionhealth.com)
Related links: Contact Latesha Walker by emailing
RAC issues to RAC@cms.hhs.gov or emailing MAC issues
to MedicareMedicalReview@cms.hhs.gov.
Breaking news:
Proposed PPS rule would trim
payments, ease face-to-face burden
Your Medicare payments would drop by a
fraction, but you’d gain considerable face-to-face
relief under the proposed 2015 PPS rule. CMS
proposes to eliminate the controversial requirement
that certifying physicians provide a narrative in their
own words explaining why the patient is eligible
for home health. For continued, in-depth analysis
of how this rule affects your agency, go to www.
homehealthline.com. To view the complete rule,
link to: http://homehealthline.decisionhealth.com/
Articles/Detail.aspx?id=518249.

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Home Health MARKETPLACE Guide | July 7, 2014 1
Home Health MARKETPLACE Guide
In this supplement
5 tips to speed physician communication,
reduce emergency room visits............................................................... 1
Have an idea for a story or a comment on an article in this
supplement? Contact Elizabeth Christian at 1-800-929-4824 x2232
or by email at echristian@decisionhealth.com.FOR HOME HEALTH CARE PROFESSIONALS
HOME HEALTH
MarketplaceGUIDE
A supplement to
5 tips to speed physician communication, reduce emergency room visits
Use advance orders and other preventive strategies
to make sure you’re able to reach physicians in the event
of an emergency. Having a plan in place may allow you
to avoid survey citations and unnecessary emergency
room visits.
In acute situations, waiting around for a physician
to call you back could land your agency in trouble. A
surveyor won’t care that the physician didn’t get back to
you when a patient comes to harm, says Ann Rambusch,
Georgetown, Texas-based clinical consultant. Your agency
is responsible for its patients, so the surveyor will want to
see that you have a solid plan in place when a physician
response is late or doesn’t come at all.
Multiple level 1 survey standards address the need to
communicate with the physician when a patient’s condition
changes. For example, G165 requires that agency staff
administer drugs or other treatments only as ordered by
a physician.
That puts you at a potential disadvantage as hospitals begin
to look for home health agencies that can help them avoid
readmission penalties starting this fall.
A.C.T. Health Care Services was recently forced to send
a patient to the emergency room because it couldn’t get in
contact with the supervising physician.
The patient’s blood pressure was close to inducing
a stroke, even though the patient had taken her blood
pressure medicine, says Tamara Salyer, administrator at the
Worthington, Ohio-based agency.
When the agency attempted to contact the physician, it
never got a return phone call.
“We could have prevented an emergency room visit had
the physician called and offered additional dosage(s) of
her blood pressure medication or called in a prescription,”
Salyer says.
Encourage physician communication
Employ these strategies to improve physician communication
and response time in the event of a patient emergency:
• Send physicians a list of vital sign parameters
that would prompt a call. The list explicitly outlines when
you will contact the physician, such as when the patient’s
pulse falls below 90BPM when at rest. You can include the
list of parameters on the plan of care as well. Make sure the
parameters are specific and outline scenarios that are likely
to come up based on the patient’s condition and history,
Rambusch says.
• Offer the physician a solution for the emergency.
If your patient is teetering on the edge of an emergency, call
the physician with a recommendation. This makes it easier for
physicians to act quickly because all they have to do is give
you a yes or no response, rather than finding a solution on their
own, Rambusch says. Physicians would much rather deal with
an assertive nurse than an unsure one, she says.
• Ask for the back office number. The benefit of this is
that physicians are much more likely to answer that line than the
main line, Rambusch says. The main line gets more traffic, and
on Friday at 4:30, the office staff may not answer, she says.
• Keep all communications as short as possible. Call
the physician and say the patient’s blood pressure is 140/90,
and you need orders to prevent a visit to the emergency room,
Rambusch says.
• Use your medical director to establish contact in
emergencies. Sometimes physicians are more inclined to
speak with another physician, Rambusch says. Most agencies
don’t use medical directors as a liaison between the physician
and the agency, even when they have them, says Arlene
Maxim, founder of A.D. Maxim Associates in Troy, Mich.
— Danielle Cralle (dcralle@decisionhealth.com)
The information in this article was current as of the date it
was printed on July 2, 2012.

2 July 7, 2014 | Home Health MARKETPLACE Guide
Home Health MARKETPLACE Guide
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