By Trudie Meeks, BSN, RN and Steve Misenko, MBA, CMS program director
If all goes well, The Joint Commission’s home care team will have some excellent news to share with infusion therapy suppliers this holiday season in the form of a deemed status option from the Centers for Medicare & Medicaid Services (CMS).
CMS has never historically covered nursing components for administering IV therapy. In 2019, CMS set the minimum expectations for suppliers to apply for and receive reimbursement, including the requirement to be accredited by an approved Accrediting Organization. The Joint Commission submitted a deeming application to CMS earlier this year and expects to achieve deeming authority by mid-December.
The requirement for home infusion therapy suppliers to obtain accreditation and become eligible for Medicare reimbursement will begin January 1, 2021. Organizations that achieve or maintain their existing home care accreditation for home infusion services by January 1, 2021 will not need to complete a new survey. If organizations are not accredited by an approved accrediting organization, they will not be able to apply for or receive reimbursement per CMS. There is no state survey option for home infusion suppliers, so accreditation on its own will be the only means of satisfying the reimbursement requirement. Organizations not currently accredited but interested in obtaining Medicare reimbursement for the nursing component of the infusion therapy service must participate in an unannounced home care survey and achieve a decision of Accredited prior to submitting requests for reimbursement.
Care Plan Element of Performance
The Joint Commission’s existing standards and elements of performance will remain in effect with minor modifications to reflect specific regulatory language regarding periodic physician review of the patient’s care plan and remote monitoring services.
Neither of the two new elements of performance should be problematic for home health organizations.
PC.02.01.03, EP #2: The patient plan of care is established and periodically reviewed by a physician and includes the medication(s) route, dose, frequency, and duration for home infusion.
It’s already a best practice for physicians to develop and monitor medication plans, so this EP will just makes it official.
Remote Monitoring Requirement
The second new element of performance reads: PC.02.02.05, EP #7: The organization provides the patient with access to nursing services, patient education and training, and remote monitoring services 24 hours a day, 7 days a week.
With the expansion of telehealth, remote monitoring is already becoming the expectation. Again, this EP formalizes an existing trend.
Early reaction from our accredited organizations has been overwhelmingly positive. With less than a year to bring newly accredited organizations up to speed in time to meet the eligibility window for CMS reimbursement, it’s going to be a busy 2020. We’re excited to start working together. Please do not hesitate to reach out to one of our home care team members.
Trudie Meeks is a project director, clinical at The Joint Commission. Prior to this, she held several positions in home health administration, risk management and clinical administration.
Stephen Misensko is The Joint Commission’s CMS program director. He has worked for The Joint Commission for more than 20 years in progressive positions within the Department of Accreditation and Certification Operations.