To qualify for home health benefits, a blind diabetic must be confined to his
home, under the care of a physician, and in need of either skilled nursing
services on an intermittent basis or physical therapy or speech -language
pathology services. Effective July 1, 1981, a person may qualify for home
health benefits based on his or her need for skilled nursing services on an
intermittent basis, physical therapy, speech -language pathology, or
occupational therapy. Effective December 1, 1981, occupational therapy is
eliminated as a basis for entitlement to home health services. However, if a
person has otherwise qualified for home health services because of the need
for skilled nursing care, physical therapy or speech -language pathology, the
patient's eligibility for home health services may be extended solely on the
basis of the continuing need for occupational therapy. (See the [Medicare
Benefit Policy Manual](https://www.cms.gov/Regulations-and-
Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS012673), Chapter
7, "Home Health Services," 20.) There must be a plan of treatment,
established and periodically reviewed by a physician, which indicates that
there is a recurring need for home health services to supplement the
physician's contacts with the patient; e.g., skilled nursing visits for
observing and determining the need for changes in the level and type of care
which has been prescribed. (See the [Medicare Benefit Policy
Manual](https://www.cms.gov/Regulations-and-
Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS012673), Chapter
7, "Home Health Services," 30.) Once an initial regimen has been established,
the frequency of need for further home health services can vary greatly from
patient to patient, depending on their condition and the likelihood of its
changing. Some may need visits only every 90 days, for example, while others
may require them much more frequently. If a nurse makes a visit to provide
skilled services, and also prefills syringes, the purpose of the visit, which
was to provide skilled services, does not change. However, if the sole purpose
of the nurse's visit is to prefill insulin syringes for a blind diabetic, it
is not a skilled nursing visit although it may be reimbursed as such as
indicated below.

Filling a syringe can be safely and effectively performed by the average
nonmedical person without the direct supervision of a licensed nurse.
Consequently, it would not constitute a skilled nursing service even if it is
performed by a nurse. (See the [Medicare Benefit Policy
Manual](https://www.cms.gov/Regulations-and-
Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS012673), Chapter
7, "Home Health Services," 30.2.2.) The personal care duties normally
performed by home health aides include assisting the patient with medications
ordered by a physician which are ordinarily self-administered. (See the
[Medicare Benefit Policy Manual](https://www.cms.gov/Regulations-and-
Guidance/Guidance/Manuals/Internet-Only-Manuals-IOMs-Items/CMS012673), Chapter
7, "Home Health Services," 50.2.)

Performance of such a service by an aide is consistent with the Medicare
conditions of participation for home health agencies. Therefore, home health
aide services would be appropriate for those blind diabetics who are qualified
for home health benefits and who cannot fill their syringes. An adequately
trained home health aide could make intermittent visits, usually on a weekly
basis, to the home for the purpose of filling that supply of insulin ordered
by the physician.

If State law, however, precludes a home health aide from prefilling insulin
syringes, payment may be made for this service as part of the cost of skilled
nursing services when performed by a nurse for a blind diabetic who is
otherwise unable to prefill his or her syringes. There are no adverse
consequences with respect to reimbursement to the home health agency for
providing the service in this manner.

If State law does not preclude a home health aide from prefilling insulin
syringes, but the home health agency chooses to send a nurse to perform only
this task, the visit is reimbursed as if made by a home health aide.

**NOTE:** As indicated, to qualify for home health benefits, a patient must
require skilled nursing services on an intermittent basis or physical therapy
or speech -language pathology. If a beneficiary does not qualify for home
health benefits but only needs someone to prefill syringes with the correct
dosage of insulin, then no program payment can be made.