CMS Pub. 100-04, ch. 10, § 20.1.1

Medicare payment for services subject to home health consolidated billing is made to the

primary HHA, so separate Medicare payment for these services will never be made. The

primary HHA is responsible for providing these services, either directly or under

arrangement. This responsibility applies to all services that the physician has ordered on

the beneficiary’s home health plan of care.

However, providing services either directly or under arrangement requires knowledge of

the services provided during the period of care. An HHA would not be responsible for

payment to another provider in the situation in which they have no prior knowledge (e.g.,

they are unaware of physicians orders) of the services provided by that provider to a

patient who is under their home health plan of care.

In certain circumstances where the primary HHA is unaware of services provided during

the period of care and the beneficiary is properly notified, the beneficiary may be liable

for payment for these services. In order to protect the beneficiary from unexpected

liability in these cases, and in order to comply with Medicare Conditions of Participation,

it is important that all providers and suppliers serving a home health patient notify the

beneficiary of the possibility that they will be responsible for payment.

Notification about home health consolidated billing must begin with the beneficiary’s

admission to home health care. Under the Medicare Home Health Services Conditions of

Participation: Patient rights, (42 CFR, §484.10 (c) (i)), the HHA must advise the patient,

in advance, of the disciplines (e.g., skilled nursing, physical therapy, home health aide,

etc.) that will furnish care, and the frequency of visits proposed to be furnished. It is,

therefore, the responsibility of the HHA to fully inform beneficiaries that all home health

services, including therapies and supplies, will be provided by his/her primary HHA.

In addition, under the Conditions of Participation: Patient liability for payment, (42 CFR,

§484.10(e)), HHAs are responsible for advising the patient, in advance, about the extent

to which payment is expected from Medicare or other sources, including the patient.

Information regarding patient liability for payment must be provided by the HHA both

orally and in writing. This should assist in alerting the beneficiary to the possibility of

payment liability if he/she were to obtain services from anyone other than their primary

HHA.

HHAs are also responsible for the timely submission of a Notice of Admission (NOA).

This ensures information about their primary HHA status is available to other providers.