Home Infusion Therapy – Accreditation and Eligibility Requirements for Billing

What are the eligibility considerations in order to bill for home infusion therapy services ?

Any examples are for illustrative purposes only.

In addition to obtaining Home Infusion Therapy (HIT) Accreditation from a CMS approved organization such as The Joint Commission, in order to bill for the new HIT benefit, the organization must be a Medicare Part B provider. Some organizations may be asking if they are eligible for the Part B benefit.

Provider Criteria
To be eligible for the Home Infusion Therapy (HIT) Medicare Part B benefit, providers need to meet the following criteria:
  • Be a home infusion therapy supplier which involves the provision of professional services (including nursing services) furnished in accordance with a physician established plan of care that describes the type, amount and duration of infusion therapy services that are to be furnished.
  • Furnish infusion therapy to individuals with acute or chronic conditions requiring administration of home infusion drugs.
  • Provide training and education, and remote and other monitoring services.
  • Ensure the safe and effective provisions and administration of home infusion therapy on a 7-day-a-week, 24 hour-a-day basis and
  • Obtain accreditation with a CMS-approved accrediting organization (The Joint Commission) by January 1, 2021
Becoming a Medicare Part B provider
Organizations interested in becoming a supplier under the HIT benefit involving professional services, training and education are required to complete and submit an application to CMS.

After you become Medicare Part B certified, in order obtain Medicare reimbursement for HIT specifically for the nursing component, your organization will need to obtain accreditation by a CMS approved accrediting organization, such as The Joint Commission. 

The HIT benefit covers services provided that are separate from those reimbursed under the Durable Medical Equipment (DME).  The service can only be billed if a professional is present on days the infusion drug is administered. The nursing component covers:
  • Specific Training and Education on the care of venous access devices (VAD).
  • Education regarding maintenance and troubleshooting 
  • Infection Control
  • Site Care
  • Ongoing patient assessments
  • Medication Management
  • Interdisciplinary Communication
Joint Commission Accreditation Requirements
The Joint Commission’s ‘Provision of Care, Treatment and Services’ (PC) remain the same with the addition of two elements of performance (EP) specific to HIT which address the Plan of Care (POC)and remote monitoring. You will be accountable for the current existing standards specific to your home care program i.e.deemed or non-deemed and the new HIT specific EPs.  The additional EPs are:
  • 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.
  • PC.02.02.05, EP 7:  The organization provides the patient with access to nursing services, including nursing services, patient education and training, and remote monitoring services 24 hours a day, 7 days a week.
Extension Survey Requirements
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. 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.

The Joint Commission HIT accreditation will satisfy the CMS reimbursement requirement.  Your organization will still need to follow the CMS application process. Questions regarding this can be submitted to  the following email address:  HomeInfusionPolicy@cms.hhs.gov. Once the entire process is completed, your organization will be accredited to provide and bill for HIT services to Medicare patients.

HIT Accreditation 
HIT accreditation is considered a new accreditation and separate from other accreditation programs. CMS is allowing organizations currently accredited to remain on their current survey schedule. These organizations are grandfathered in for HIT accreditation until the organization’s next scheduled survey. However, it is necessary to implement the new, unique HIT Elements of Performance for compliance with the program. 

Resources:
Medicare Provider-Supplier Enrollment
Palmetto GBA National Supplier Clearinghouse MAC
Special payment rules for items furnished by DMEPOS 
Fact Sheet For Home Infusion Therapy Providers Serving Medicare Patients
Medicare Part B Home Infusion Therapy Services
Last updated on June 30, 2020
Manual: Home Care
Chapter: Provision of Care Treatment and Services PC

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