Information presented during the April OASIS CMS conference has led to a misunderstanding about the requirements for physician authorization or collaboration under a home health plan of care. The following is CMS' clarification:

Q: Although it is a responsibility of the home care clinician to gather all applicable information and identify the HOME CARE primary diagnosis, i.e., the focus of the home care plan of care that is ultimately reviewed and signed by the physician, is further contact with the physician expected and required by CMS?

A: We would like to clarify any misunderstanding or misconception from the April 1, 2003, OASIS conference. There is no change in policy or process which directs any further physician collaboration or authorization than an HHA (home health agency) is already expected to do in order to be compliant with 42 CFR 484.18(a). The [HHA][horizontal ellipsis]is expected to remain compliant with 42 CFR 484.18(a) which stipulates: "The plan of care developed in consultation with the agency staff covers all pertinent diagnoses, including mental status, types of services and equipment required, frequency of visits, prognosis, rehabilitation potential, functional limitations, activities permitted, nutritional requirements, medications and treatments, any safety measures to protect against injury, instructions for timely discharge or referral and any other appropriate items. If a physician refers a patient under a plan of care that cannot be completed until after an evaluation visit, the physician is consulted to approve additions or modifications to the original plan[horizontal ellipsis]."

It is also expected that home health agencies remain complaint with 42 CFR 409.43(e), which stipulates: "The plan of care must be reviewed by the physician (as specified in 42 CFR 409.42(b)) in consultation with agency professional personnel at least every 60 days or more frequently when there is a

i. Beneficiary elected transfer;

ii. Significant change in condition resulting in a change in the case-mix assignment; or

iii. Discharge and return to the same HHA during the 60 -day episode[horizontal ellipsis]."