On August 1, 2014, CMS issued Transmittal 192, specifically updating section 60.4.1 of Chapter 15 of the Medicare Benefit Policy Manual (Pub 100-02) to provide clarification of the definition of "confined to the home" (homebound). The update is intended to bring the manual guidance in line with the 2012 HH PPS final rule that was published on November 4, 2011 (76 FR 68599-68600. The clarification was recommended by the Office of Inspector General (OIG).
CMS states that the changes closely align the policy manual with the requirements of the Social Security Act. The new clarification is intended to prevent confusion, promote a clearer enforcement of the statute, and provide more definitive guidance to HHAs in order to foster compliance.
The clarification should help HHAs in the audit process and provide clearer guidance to HHAs and auditors going forward.
A copy of the manual transmittal can be found here - http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R192BP.pdf
The associated MLN - MedLearn Article can be found at - http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8818.pdf
For more information on home health care and Medicare, please feel free to contact Ari Markenson at amarkenson@duanemorris.com or 212.692.1012.
