Refresh: Home Health Timely Initiation of Care Process Measure

by Lori Marmon PT, MBA, COS-C

The Timely Initiation of Care (TIOC) measure not only impacts quality metrics but also reflects a standard of best practice for the home care patient population. This measure is looking at the percentage of home health quality episodes where the Start of Care (SOC) or Resumption of Care (ROC) was on the physician ordered date (if provided and then coded in M0102) or otherwise within 2 days of the referral date (M0104) or the inpatient discharge date (M1005), whichever is later.

In plain language, this means that to have both a favorable outcome for the measure AND for best practice for the patients, home health services need to start or resume within 2 days of the inpatient discharge or referral to the agency, or on the date the physician/allowed practitioner ordered.

Let’s start by looking at the guidance for M1000-Inpatient Facilities and M1005-Inpatient Discharge Date. With the M1000 item, we are reporting from which inpatient facility was the patient discharged during the past 14 days. A piece of guidance to keep in mind for this item is that if the patient had been admitted to the hospital as an inpatient, it is considered a hospital discharge.

If the patient was not admitted as an inpatient but placed under observation status (utilizing a G-codes for hospital outpatient department observation services), then it would not be an inpatient facility discharge and therefore not reportable in M1000 (CMS OASIS Q&As Cat 4b, Q32.3). If the patient was NOT discharged from an inpatient facility in the past 14 days, M1005- Inpatient Discharge Date is skipped.

M1005 reports the most recent discharge date from an inpatient facility that has occurred within the last 14 days. So, for the purposes of calculating the TIOC measure, if the patient was discharged from an inpatient facility and the Inpatient Discharge Date (M1005) is AFTER the Date of Referral (M0104), the Inpatient Discharge Date is the date used for the measure calculation.

M0104-Date of Referral is the most recent date that verbal, written, or electronic authorization to begin or resume home care was received by the home health agency.

A valid referral is considered received when the agency has received adequate information about a patient (such as name, address/contact info, and diagnosis and/or general home care needs) to initiate patient assessment and confirmed that the referring physician/allowed practitioner or another physician/allowed practitioner, will provide the plan of care and ongoing orders.

In cases where home care is requested by a hospitalist who will not be providing an ongoing plan of care for the patient, the agency must contact an alternate or attending physician/allowed practitioner. The agency will note the date the alternate or attending physician/allowed practitioner agreed to follow the patient as the referral date (M0104) unless referral details are later updated or revised.

Coming back again to the calculation of the TIOC measure, the date that will be used to determine the “start” of the 2 days to initiate or resume the care will be the LATER of:

  • The M1005 date if the patient was an inpatient in a facility and discharged in the previous 14 days
  • The M0104 date once all the components of a valid referral are present

There is one more consideration for this measure and that is M0102- Date of Physician-ordered Start of Care (Resumption of Care).

M0102 reports the date specified by a physician/allowed practitioner order to start home care services or resume home care services regardless of the type of services ordered. To be considered a physician-ordered SOC/ROC date, the physician/allowed practitioner must give a specific date to initiate or resume care, not a range of dates.

If a single date to initiate or resume services is not provided, the initial contact (via the initial assessment visit or ROC visit) must be conducted within 48 hours of the referral or within 48 hours of the patient’s return home from the inpatient facility.

If a new or updated physician’s ordered start or resumption of care date is to be reported, it must have been received before the end of the 48-hour initial assessment timeframe (or before the date of the previous physician’s ordered start of care/resumption of care date if one was provided) (CMS Q&As Cat 4b Q23.11.2.2).

If there is a date accurately reported in M0102 as the physician ordered SOC or ROC date, this date is used in the TIOC measure calculation as M0104 is skipped when there is a date provided for this item.

Implementing accuracy in coding and understanding of the guidance for these OASIS items that are used to evaluate a home health agency’s use of good processes for care can reflect a home health agency’s focus on evidence-based best practices for their patients.

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