Home Health Billing

Home Health Agency Transfer and Dispute Protocol

Specific protocol and steps must be followed prior to opening an admission period for a new patient.

  1. Step One: Verify the patient’s eligibility

    • You must ensure the patient is not receiving services from another HHA. If you find there is an open home health admission period established when verifying eligibility (i.e., the patient status is 30 or there are no dates reflected under DOEBA/DOLBA), this means the patient is still considered a patient with another HHA and must be treated as a transfer. It may also be helpful to talk to the patient about any services they are currently receiving in their home.

  2. Step Two: Coordinate the transfer with the initial HHA

    • The receiving HHA is responsible to coordinate the patient’s transfer. The receiving HHA’s records must contain a copy of a dated telephone log showing that contact was made with the initial HHA on the effective date of transfer, and notating that the initial HHA was advised of the patient’s decision to transfer. This must include the date and time the call was made, and the personnel contacted. The initial HHA must also properly document that it was contacted and that it accepted the transfer.

  3. Step Three: Advise the patient of transfer protocol

    • You are required to advise the patient that they cannot receive services from two HHAs at the same time. Your records must include a signed and dated copy of the patient admission package which shows language explaining to the patient that their decision to transfer allows the receiving agency to become the primary HHA, and that the initial HHA will no longer provide care for the patient and will no longer receive Medicare payment for the patient’s care.

Please be aware that all of the above steps must be completed and the appropriate documentation must be in your records if you file a dispute with us.

Note: If an HHA’s NOA is returned in the Medicare claims processing system as an overlap with another provider, you cannot resubmit the NOA with a condition code 47 unless the above procedures have been followed. It is the responsibility of each HHA to work with other HHAs in a transfer situation. If the HHAs are not able to settle the dispute between them, contact the beneficiary and ask which HHA they prefer to be the provider of services. If the beneficiary states they want to stay with the first established agency, then the second agency cannot bill for any services provided. If the beneficiary states they want to go with the second agency, then the first HHA cannot bill any services after the date the second HHA started care. If the HHAs cannot settle the dispute and the beneficiary does not want to choose between the HHAs, only then should a transfer dispute be filed with the MAC.

Transfer disputes should not be a common occurrence. It is up to each HHA to properly communicate with other providers of care, including other HHAs.

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Reviewed 5/20/2024