[Updated] CMS Loosens Medicare Homebound Requirements, Suspends Review Choice Demo

Home health providers are receiving more temporary policy support in response to the novel coronavirus pandemic.

On Monday, the U.S. Centers for Medicare & Medicaid Services (CMS) announced another round of COVID-19 regulatory waivers and new rules aimed at reinforcing the operations of Medicare-reimbursed providers. Among changes for home health agencies, in particular, CMS stated that it is loosening Medicare homebound requirements while also suspending the Review Choice Demonstration (RCD).

Home health advocates have been calling for both moves since the COVID-19 crisis elevated into a national emergency.


“Every day, heroic nurses, doctors and other health care workers are dedicating long hours to their patients,” CMS Administrator Seema Verma said in a statement. “This means sacrificing time with their families and risking their very lives to care for coronavirus patients. Front line health care providers need to be able to focus on patient care in the most flexible and innovative ways possible.”

Normally, patients are only eligible for home health services if they’re confined to the home due to illness or injury — or because leaving home requires “a considerable and taxing effort.”

In the context of COVID-19, home health providers feared that relatively rigid rule would leave some isolated individuals in danger.


CMS addressed that specific concern on Monday.

“If a physician determines that a Medicare beneficiary should not leave home because of a medical contraindication or due to suspected or confirmed COVID-19, and the beneficiary needs skilled services, he or she will be considered homebound and qualify for the Medicare Home Health Benefit,” CMS noted in its announcement. “As a result, the beneficiary can receive services at home.”

When it comes to RCD, CMS is giving home health agencies the option of pausing their participation for the duration of the COVID-19 national emergency. Home Health agencies do not have to do anything for the pause to go into effect.

RCD states include Illinois, Ohio, Texas, North Carolina and Florida.

Apart from the RCD suspension and loosening of homebound requirements, CMS said it is further promoting telehealth in Medicare, an action Congress asked for in the recently enacted CARES Act.

Building on prior action to expand reimbursement for telehealth services to Medicare beneficiaries, CMS will now allow for more than 80 additional services to be furnished via telehealth, according to the agency.

Providers also can evaluate beneficiaries who have audio phones only.

“CMS is expanding access to telehealth services for people with Medicare,” the agency touted. “This means they can receive care where they are: at home or in a nursing or assisted living facility. If they have COVID-19, they can remain in isolation and prevent spread of the virus. If they aren’t infected, they can get care without risking exposure to others who may be ill.”

Home health care has largely been left out of CMS’s previous telehealth expansions, apart from flexibilities surrounding physician face-to-face requirements.

On Monday, CMS announced that home health agencies can provide “more services to beneficiaries using telehealth,” so long as it is part of the patient’s plan of care and does not replace needed in-person visits as ordered on the plan of care.

But it’s somewhat unclear what the phrasing truly means.

There still appears to be no mechanisms for home health providers to get paid for visits delivered via telehealth technology, multiple home health policy experts told Home Health Care News.

HHCN asked CMS for telehealth-reimbursement clarification during a Monday night conference call with members of the media.

“I think the key is services provided to the patient have to be according to the plan of care that’s been set up by the physician in ordering home health,” a CMS official told HHCN. “But the payment for the 30-day episode would include payment for the telehealth visits.”

Essentially, CMS is saying that the 30-day episodic payment is meant to also fund the telehealth, though maintaining that telehealth visits do not count as individual billable visits, another industry source told HHCN.

In other good news for home health providers, CMS is also waiving requirements for a nurse to conduct an on-site visit every two weeks for home health and hospice.

“This would include waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan, as this may not be physically possible for a period of time,” CMS stated.

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