This memorandum is to reaffirm current Medicare policy regarding skilled nursing care as a qualifying service for the home health benefit. As you know, to receive reimbursement for home health care a beneficiary must be under the care of a physician who has certified that medical care in the home is necessary and who has established a plan of care for the beneficiary. The beneficiary also must be confined to the home and must need intermittent skilled nursing services, physical therapy or speech language pathology, or have a continuing need for occupational therapy. The venipuncture provision in the BBA, Section 4615, removes blood draws from the list of skilled nursing services that qualifies a beneficiary for home health care.
Venipuncture is the withdrawing of venous blood, typically used for analysis of the blood sample.
If the beneficiary only needs blood drawn, he or she will not qualify for the home health benefit. However, if an individual requires skilled therapy or nursing services, he or she can continue to receive home health services, including venipuncture. Recently, HCFA responded to a letter from Representative Bill Thomas, Chairman of the House Subcommittee on Health, which presented several clinical case studies concerning the venipuncture provision. Our response reflects current Medicare policy on home health skilled services, which will be explained below in more detail. This response does not reflect new policies, just application of the current policy principles to the case studies relying upon informed clinical assumptions about the patients in the study.