For home infusion therapy (HIT) suppliers, the Medicare Conditions for Coverage (CfCs) apply to an organization as a whole — including all clients/patients and not just Medicare beneficiaries.

But there is some flexibility. Organizations that provide services to both Medicare and non-Medicare clients/patients — and want to have Medicare regulations apply only to Medicare beneficiaries — can establish a viable separation of services.

Organizations that see the most benefit from separating clients/patients for services include Pharmacy Infusion Nursing (IRN) providers and Home Care Nursing (HCN) providers that also offer Medicare-regulated Home Infusion Therapy Supplier (HITS) services.

To receive Medicare reimbursement for HITS services, organizations must be accredited by an approved accreditor like Accreditation Commission for Health Care (ACHC).

During Your Survey

During an ACHC Home Infusion Therapy Accreditation survey, the Surveyor should be able to observe and identify that your organization differentiates services between IRN and HITS services or between HCN and HITS services.

Establishing Separate Services

The following criteria should be met to establish a separation of services for your organization.

Organization Operations

• Separate clinical records must be kept for clients/patients receiving IRN and HITS services or HCN and HITS services.
• Additional policies are established that address separate requirements for the provision of HITS services.
  • For example, the CfCs require a physician to approve and periodically review the Medicare beneficiary’s plan of care for HITS services. For IRN or HCN services, a nurse practitioner or physician assistant can write orders and review the plan of care, if allowed by state laws and regulations.

Consumer Awareness

• Marketing materials should be reviewed to verify that the materials note the differences between HITS services and IRN or HCN services.
• Written materials should clearly identify the HITS services as separate and distinct from the IRN or HCN services.

Staff Awareness

• Staff should be able to identify differences in the HITS, IRN, or HCN services they provide.

Here to Help

ACHC is your partner in accreditation. For more information, contact your Account Advisor, email [email protected], or call (855) 937-2242.