Are You A Medicare Certified Home Health Agency Who Doesn't Really See Medicare Patients? Could You Be Targeted For Deactivation?

If you are members of the National Association for Home Care and Hospice or your respective state associations, then you may have already heard of the "Organization Deactivation Project 2022".  If not, then your agency may be at risk if you haven't been servicing Medicare patients in the last year.

Many states without licensure require agencies to be Medicare certified in order to meet state requirements for providing services to Medicaid and other non-Medicare payers. So, Medicare certification was a necessity and servicing Medicare patients was not necessarily your target for market share. It appears some agencies have already received letters from their Medicare Administrative Contractor (MAC) if they have not submitted Medicare claims in the past 12-13 months. Ultimately, those organizations in business to serve only Medicaid will want to consider marketing for some Medicare patients. Now, an agency that never plans to bill Medicare may not see an issue with deactivation of Medicare billing privileges. It becomes an issue if CMS wants to potentially revoke enrollment in the Medicare system which would negatively impact those states that have no choice but to be Medicare certified. An agency would then potentially need to submit a new 855 and start the enrollment process for Medicare all over again to bill for services. This would be costly for providers who would be going through additional survey and providing care for free during the interim. Ultimately, this may a be hard push from CMS for states without licensure to put it in place. From the federal level, you can see how this would make sense. It makes the states wholly responsible for those Medicare certified agencies billing for only for Medicaid and non-Medicare payers within the state.

If CMS is looking into this, then agencies servicing only Medicaid and Medicaid waivers need to look closely at their patients. Are your dually-eligible patient qualifying for the Medicare home health benefit at different times but not being discharged from a Medicaid plan of care? Now, we have no confirmation that this is something CMS is looking at, but it could potentially show the states that Medicaid dollars are going to patients who qualify for Medicare services. At Kenyon Homecare Consulting, we encourage all agencies to belong to their respective state associations as well as NAHC. There is a wealth of education, advocacy, and resources for agencies. If you need individual consulting or education,  please call Kenyon Homecare Consulting at 206-721-5091 or contact us online to see if we can help you achieve your clinical, operational, and financial goals.