Nurses General Nursing
Published Aug 7
Kcalicutt
12 Posts
I am a home health nurse and have been one 5.5 years. I have only ever done actual nurse visits- including oasis. My company is providing M&E visits free of charge as medicare no longer pays for them. My thought is they are attempting to show it is needed and get medicare to once again allow these. My question is CAN a nurse (RN) perform a HHA visit legally?? I am aware that it is in a nurses scope of practice to perform such things a HHA does. But is an RN legally allowed to chart a HHA visit signing as an RN. My thoughts would be it would need to be an actual nurse visit not a nurse performing and charting under a "HHA" visit. If anyone knows I would appreciate it. I have been trying to find the legalities and have not had much luck.
JKL33
6,895 Posts
Can you specify abbreviations as used here? Is HHA home health aide? And what does M&E then stand for in this context?
I probably can't answer your questions but more people may be able to help if we know full search terms. Thanks!
OnceIWas
22 Posts
I've worked HH for years & have no idea what M&E is - if you explain maybe I can answer your question.
The agency I worked for, when short staffed, would schedule an LPN or PTA for HHA visits. It was legal and they documented whatever they did - bath, etc. Their credentials - PTA or LPN were documented upon signing their documentation for the patient.
HHA = home health aide
M&E = Management and Evaluation
basically it's a program that allows a HHA to go and do the prescribed therapy exercises with the patient, assist them in doing these. And then supervise visits every so often by an RN. However my agency does not have a HHA and is not planning on hiring one at this time.
FolksBtrippin, BSN, RN
2,222 Posts
Yes an RN can legally do an HHA visit. I would not agree to do this though. At my last home hospice company in 2021, we had a shortage of aides and I wound up giving some of my patients bed baths as part of my RN visit, because they needed one and I knew no aide was coming. I documented in my note that I gave a bed bath. I was the only nurse that did this. Pretty soon, the office started scheduling me for aide visits. I had to tell my manager no. I am a nurse, and if my patient needs a bath I am giving them one, but that doesn't mean they get to use me like that. That having been said, you do you. If you are okay with it, then it's okay. Think about it though. How many bed baths are you willing to give? Are you helping out or are you working below your ability? You will have to figure out what works for you.
Another personal example for me, is that when I used to work inpatient psych, once in a while I would get pulled to the tech position, or as a sitter. That was okay if they really needed a 1-1, but if they're doing it all the time or if I'm the only one getting pulled like that, it was a problem for me.
Advocate for yourself.
Thanks for the responses. I'm actually 100% not comfortable with it which is why I was looking into seeing if it was even legal for them to be trying this. I was hired for a reason and that was not it. Not saying that role is beneath me or anything but that's not what I was hired to do.
Never heard from M&E for home health..are these medicaid patients? You also mention therapy - like physical therapy?
HHA in traditional (medicare) home health attend to personal care, some light house keeping (changing the bed, light meal) but providing therapy - no.
Maybe I am misunderstanding what type of agency you are working for but the bottom line is - if YOU aren't OK with what is being asked of you - it's up to you to let your bosses know & figure out a solution. If they can't offer one than that would be a signal to find another job.
NRSKarenRN, BSN, RN
10 Articles; 18,721 Posts
During flu season/aide car accident/aide suddenly quit, I've performed aide care in addition to scheduled visit for my client --rare occurance. To hear that they don't plan on replacing a home health aide, has my antenae up!
If your Home Health agency is Medicare/Medicaid certified, they need to follow Medicare Home Health Conditions of Participation to remain in business and get paid for care provided.
1. Home Health Agency needs to provide at least TWO services with own employees, can subcontact other disciplines when needed to meet clients plan of care.
§ 484.105 Condition of participation: Organization and administration of services.
Quote Skilled nursing services and at least one other therapeutic service (physical therapy, speech-language pathology, or occupational therapy; medical social services; or home health aide (HHA)ha services) are made available on a visiting basis, in a place of residence used as a patient's home
Skilled nursing services and at least one other therapeutic service (physical therapy, speech-language pathology, or occupational therapy; medical social services; or home health aide (HHA)ha services) are made available on a visiting basis, in a place of residence used as a patient's home
2. Agency must provide ALL SERVICES listed on 485 plan of care ordered by physician/NP at start of care:
Quote § 484.50 Condition of participation: Patient rights (C). (5) Receive all services outlined in the plan of care.
§ 484.50 Condition of participation: Patient rights
(C). (5) Receive all services outlined in the plan of care.
3. Specific education required by home health aides in order to bill for aide services listed under this section of regs:
Quote § 484.80 Condition of participation: Home health aide services. an agency can't discontinue services merely because it doesn't have enough staff.
§ 484.80 Condition of participation: Home health aide services.
an agency can't discontinue services merely because it doesn't have enough staff.
Therefore, during periods of staffing crisis an RN or LPN can provide aide care incidental to a nursing visit or in place of a HHA as these skills taught as part of basic nursing education. However, they cannot not bill using a HHA visit code if only aide care provided. Please get clarification from you Clinical Manager regarding which aide will provide care for next scheduled HHA visit.
If this is a new startup, they may not be aware of all they home care regulations. Feel free to message me as 40+yrs homecare: field staff, Manager, QA and utilization review. Not getting satisfaction with management answers or have documentation of agency not meeting above standards
If you suspect fraud call 1-800-MEDICAR ; online: https://tips.oig.hhs.gov/
Off to look for Management an Evaluation powerpoint I developed; review CMS regs
Management and Evaluation of a Patient Care Plan
Medicare Benefit Policy Manual Chapter 7 - Home Health Services
Quote 40.1.2.2 - Management and Evaluation of a Patient Care Plan (Rev. 265, Issued: 01-10-20, Effective: 01-01-20, Implementation: 02-11-20) Skilled nursing visits for management and evaluation of the patient's care plan are also reasonable and necessary where underlying conditions or complications require that only a registered nurse can ensure that essential unskilled care is achieving its purpose. Once the recovery is complete and/or medical safety is achieved (I.e., the beneficiary's care plan is unchanging), management and evaluation of the care plan is no longer reasonable and necessary.
40.1.2.2 - Management and Evaluation of a Patient Care Plan (Rev. 265, Issued: 01-10-20, Effective: 01-01-20, Implementation: 02-11-20) Skilled nursing visits for management and evaluation of the patient's care plan are also reasonable and necessary where underlying conditions or complications require that only a registered nurse can ensure that essential unskilled care is achieving its purpose.
Once the recovery is complete and/or medical safety is achieved (I.e., the beneficiary's care plan is unchanging), management and evaluation of the care plan is no longer reasonable and necessary.
Skilled Management and Evaluation case checklist to consider includes:
This is a NURSING ORDER I use when need to recert an unstable client; discharged client after 2 certs but back in emergency room within 60 days as medicaid aide didn't help client follow care plan; client so forgetful just got new aide and neighbor to care for him.
Unskilled caregiver needs supervision to ensure care consistently done ( e. g. missed doctor appointments, ostomy/catheter full-not emptied, wound healed - new coccyx redness, new heart failure diet not understood -7lb weight gain in 1 week at end cert period).
Visit pattern example:
SN: 1x/wk x2, q2 weeks x2; 1-2x month + 2PRN for following problems
Locator 21 on care plan: List problems
• medication management
• bowel elimination
• ostomy/catheter management assessment of new device
• Multiple unskilled caregivers
• patient has more than one problem to manage e.g. CHF with diabetes
• caregiver fails to refill meds on timely basis increasing risk hospitalization
• Nutrition at risk: lack of adequate food intake, weight loss, constipating meds
• Slow healing wounds that required change treatment
• Unskilled caregiver needs supervision to ensure care consistently done (missed doctors appointment).
CARE PLAN LOCATOR 22: List individual goal for each case managed problem
Each visit must
Management and Eval ends when
See client scenerio examples in Chapter 7 link above for further understanding.