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From Health Law Daily, August 31, 2015

CMS gives home health agencies 90 days to report location change

By Kayla R. Bryant, J.D.

Home health agencies (HHAs) that move to a new site or location must notify the Medicaid administrative contractor (MAC) within 90 days of the move. CMS updated regulations to resolve a conflict in the number of days required. HHAs that do not update this information within the timeframe are in danger of losing billing privileges (CMS Letter, S&C: 15-51-HHA, August 28, 2015).

State Operations Manual. Section 2185 of the State Operations Manual (SOM) requires that an HHA update its MAC within 30 days of moving to a new location, including submitting an amended Form CMS-855A. However, the provider enrollment regulations provide for a 90-day notification time frame (42 CFR 424.516(e)(2)). To resolve this inconsistency, CMS updated the SOM to specify a 90-day notification timeframe, effective immediately.

Notification of the move allows CMS to determine whether the HHA is complying with conditions of participation at the new location. The move must be to a new site within the approved geographic area to qualify. According to the SOM, the change of location will not be approved if a branch location moves far enough from the parent location that the HHA will not be able to exercise supervision and control necessary to ensure that the branch offers satisfactory quality of care to its patients.

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