CMS Pub. 100-02, ch. 15, § 320.5.2

Depending on patient acuity or the complexity of the drug administration, certain

infusions may require more training and education, especially those that require special

handling or pre-or post-infusion protocols. The home infusion process typically requires

coordination among multiple entities, including patients, physicians, hospital discharge

planners, health plans, home infusion pharmacies, and, if applicable, home health

agencies.

For payment purposes, all services billed to Medicare by the qualified home infusion

therapy supplier must be reflected in the plan of care, which is required to be established

and reviewed by the physician. Section 1861(iii)(1)(B) of the Act requires that the plan

of care be established and periodically reviewed by a physician in coordination with the

furnishing of home infusion drugs. This means that the plan of care must be established

and reviewed by a physician in consultation with the suppliers responsible for furnishing

the home infusion drug and related services. “The statute does not specify that the home

infusion plan of care must be established by the same physician who orders the DME and

infusion drugs and signs the detailed written order. It is expected that in most cases the

physician ordering the home infusion therapy services is the same physician ordering the

DME and the infusion drug, however, this may not always be the case. Furthermore, if a

hospital-based physician initially orders the infusion drug and/or the home infusion

therapy services for a patient, they will likely not continue to follow the patient after

discharge; however, in order for the patient to continue to receive home infusion therapy

services, that patient must be under a physician-established plan of care that is reviewed

periodically. Any updates to this plan of care would not likely be made by the hospital-based physician, rather by whichever physician that takes over the patient’s care after

hospital discharge. In this case, a physician serving as the “applicable provider” as

described in section 320.4 could also be the “ordering physician” as mentioned in section

320.5. Regardless of whether the physician ordering the home infusion drug is the same

physician ordering and updating the home infusion therapy services, there must be care

coordination among all entities in order to meet the plan of care requirements.”

The physician establishing the plan of care is required to consult with the DME supplier

and the home infusion therapy supplier. In order to ensure that home infusion therapy is

safe and effective and stays current throughout the course of treatment, the physician who

orders the home infusion therapy services must review the plan of care on a regular basis

in coordination with the DME supplier. The DME supplier is also required to consult

with the physician prescribing the infusion drug as needed to confirm the drug order and

any necessary changes, refinements, or additional evaluation to the prescribed equipment

item(s), and/or service(s).

The plan of care plays an integral part in care coordination between providers,

particularly when the physician ordering the home infusion drug is not the same

physician establishing the home infusion therapy services plan of care. Coordination

between the physician ordering the home infusion drug, the physician establishing the

plan of care for the home infusion therapy services, and the DME supplier furnishing the

home infusion drug is imperative in providing safe and effective home infusion therapy.

Coordination would likely include review of the patient assessment and evaluation,

including interpretation of lab results as they pertain to changes in medication type, dose,

or frequency. A current home infusion therapy services plan of care is essential in order

to ensure that the qualified home infusion therapy supplier is providing the appropriate

professional services, including patient monitoring, to ensure that medication

administration is safe and effective.

As coordination is required between the DME supplier responsible for furnishing the

infusion drug, and both the physician establishing the home infusion therapy services

plan of care and the prescriber of the home infusion drug, all entities are expected to be

involved in this care coordination process.