The initial assessment and start of care (SOC) comprehensive assessment are two separate requirements under the Conditions of Participation (CoPs) and, therefore, different from each other, even though both can be done at the first visit in the home.
Moreover, due to COVID-19 public health emergency (PHE), the Centers for Medicare & Medicaid Services (CMS) has set waivers that give agencies more flexibility to carry out the initial assessment and collect data for the SOC comprehensive assessment. To recall, the U.S. Department of Health and Human Services (HHS) announced on April 13, 2022 the extension of the PHE for another 90 days until July, keeping useful home health waivers in place.
Let us understand the distinctions between the two and identify what has changed with the waivers granted by CMS for the COVID-19 PHE.
The initial assessment visit determines the patient’s immediate care and needs for support, and if the patient is eligible for coverage under the Medicare home health benefit. These are the questions that need to be answered during this visit:
- Is the patient homebound?
- Is the patient under the care of a physician?
- Is the patient in need of skilled services?
- Has the patient had a face-to-face encounter with a medical provider as mandated by the Affordable Care Act?
The initial assessment visit must be done within 48 hours of the patient’s referral to home care or return home from the inpatient facility, or on the physician-ordered start of care date. This waiver for the COVID-19 PHE, which only applies to the initial assessment, allows the agency to carry out the initial assessment remotely via phone call or by medical record review instead of going to the patient’s home for an actual in-person visit. This determination must still be completed within 48 hours of the patient’s referral or return home without requiring a home visit within that period.
SOC Comprehensive Assessment
While the initial assessment can be done remotely and does not require an in-person visit, the SOC comprehensive assessment does. It must evaluate the patient’s physical, functional, mental, psychosocial, and cognitive status to identify the patient and caregiver’s needs, which will be addressed by the home health agency’s services. This particular assessment at SOC includes the collection of OASIS data and must be completed within 30 days after the SOC date or the first reimbursable visit. This time frame of 30 days under the COVID-19 PHE changes has been extended from the previous 5-day window to complete data collection prior to the COVID-19 PHE.
In the interest of efficiency, many agencies encourage the admitting clinician to complete the SOC comprehensive assessment in the initial visit as well. In this case, the SOC date (M0030) is the same as the date that the assessment is completed (M0090). These protocols and procedures are a matter of agency choice and agency policy, as long as the regulatory time requirements are met and an appropriate professional performs the task based on the patient’s case.
- For a Skilled Nursing (SN) only case, the Initial Assessment, and SOC Comprehensive Assessment can both be accomplished by an RN on the first visit to the patient’s home.
- For a Physical Therapy (PT) only case, the Initial Assessment CAN be done by an RN, in the absence of a PT. However, it is mandatory that a PT should complete the SOC Comprehensive Assessment. Otherwise, a PT can accomplish both at the first visit to the patient’s home.
- For an SN/PT mix case, either an RN or a PT can conduct the Initial Assessment. However, the SOC Comprehensive Assessment is usually done by an RN in most cases.
To ensure compliance with the Home Health Quality Measure for Timely Initiation of Care, make sure your initial assessment date is within 48 hours after the patient’s referral to home health. Although the OASIS check integration in your EMR will prompt you for this, it is best to have it double-checked by your QA team or provider.