On April 7, 1998 the Centers for Medicare & Medicaid Services (CMS) (at the time called the Health Care Financing Administration (HCFA)) issued a memorandum clarifying home health coverage criteria with respect to:  (1) the new venipuncture limitation; (2) the on-going availability of coverage for observation and assessment by a licensed nurse; and (3) management and evaluation of a patient care plan.  The memorandum is particularly important in that it makes useful comments about the continued availability of Medicare coverage regardless of whether the person's condition is chronic, stable, or will extend over a long period of time.  We received this memorandum on April 10, 1998.

As the memorandum is very recent, it will be a while before we know how regional administrators, medical directors and regional home health intermediaries will apply it.   Nonetheless, we think it provides an important advocacy tool for addressing important aspects of home health coverage criteria. 

The receipt of this information is the result of correspondence with HCFA following a request to the Administrator for clarification of HCFA policy. The National Senior Citizen Law Center, the Medicare Advocacy Project (Boston, MA) and the Center for Medicare Advocacy, Inc. requested that HCFA clarify its policies following the onslaught of home health care coverage denials that we began seeing in January if this year.  It is important to note that these increases began just as the Medicare Interim Payment System (IPS) for home health care became effective.

A copy of the April 7, 1998 HCFA Memorandum is available from the Center.  Click here to view the HCFA Memorandum.