Medicare cares whether a visit was billable

Question: We have a patient that did not get a face-to-face until after the 30-day mark after SOC.  I know I can go 30 days prior to when the face-to-face took place. When I count back, the patient was seen by a therapist that day but was not seen by a skilled nurse until several days later.  Do I have to have the clinician do an OASIS/485 for the date she saw? The specifics:

HH original SOC 6/29
Face to Face encounter 8/9
Possible new SOC 7/11 (30 days prior to 8/9)
SN saw 7/9, therapy saw 7/11, SN saw 7/20

Do all consent forms need to be redated to new SOC date as well?  New 485, new OASIS?

Lisa says: Your new SOC should be generated based on a date of 7/11 (30 days back from F2F was 7/11). 7/11 is chosen because it is the first eligible date and the first billable visit was made. Medicare doesn’t care who made the visit as long as it was billable.
 
To generate a new SOC assessment, any qualified clinician can sit down with the old SOC and complete the new one based on the same answers with updates to M0110 and M2200. A new 485 will need to completed with updated orders to reflect the 60 days beginning with 7/11 as the “from” date. M0090 will be the actual date that the new SOC is generated so you will receive late warnings.
 
Medicare does not speak to new consents, but I suggest you at least have some kind of communication with the patient in the interest of patient rights. This could get signed at the next visit. For example:

Dear {Patient},

A visit with your physician within a certain time frame when beginning care with a home health agency is a condition of payment for the home health agency. Because you did not see your physician until {date}, we have a new start of care date for you and the care previous to the date is non-covered by Medicare. (You are not responsible for payment.)

We will continue to provide you care under the previous consent forms signed by you or your representative. Please sign this letter to indicate your receipt of this information.

Regards.

Administrator Signature                                                              Patient Signature

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