The first visit to the home is the ROC

Some agencies are under the impression that the first visit after the patient returns from an inpatient facility stay has to be the ROC assessment and they believe that any visit prior to the ROC assessment cannot be billed. Both are misunderstandings. The first visit by anyone by your agency, billable or non-billable, is the ROC visit and so the date of that visit is placed in M0032. The ROC assessment has to be completed within 48 hours of return home.

Here is the information from OASIS Q&As

[Q&A ADDED & EDITED 9/09; Previously CMS OCCB 01/09 Q&A #5]

Q15.1. My patient was released from the hospital and needed an injection that evening. The case manager was unavailable and planned to resume care the following day. Could the on call nurse visit and give the injection before the resumption of care assessment is done? Is there a time frame in which care (by an LPN or others) can be provided prior to the completion of the ROC assessment?

A15.1. There are no federal regulatory requirements that prevent an LPN from making the first visit to the patient when resuming care after an inpatient facility stay, but there must be physician orders for the services/treatments provided during that visit. It is not required that the ROC comprehensive assessment be completed on the first visit following the patient’s return home. OASIS guidance states that the Resumption of Care comprehensive assessment must be completed within 2 calendar days after the patient’s return from the inpatient facility. The clinician that completes the ROC comprehensive assessment must be an RN, PT, OT or SLP.

In the case of an unknown hospitalization, a LPN/LVN, aide, or PTA etc makes a regularly scheduled visit and finds that the patient has had a hospitalization meeting the criteria for transfer, calls the agency and reports the hospitalization. The orders you have for the episode are still valid orders after an inpatient admission, so if that regularly scheduled visit has orders that visit is still billable. That visit date is also the date placed in M0032. The qualified clinician has 2 days from the point of acquiring the knowledge of the hospitalization to complete the transfer and the ROC assessments. M0090 is the date the assessment was actually completed.

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