Home Health Care

Home Care Fee Schedule Possibilities Considered

A RAND Center report highlights the difficulties of creating a fee schedule and related coverage policies for home health services.
By: | February 6, 2015

“The task that [the Division of Workers’ Compensation] faces in establishing a fee schedule for home health services that meets the requirements imposed by the Labor Code is difficult,” stated a new analysis. “Weaving multiple fee schedules into a single integrated fee schedule is challenging in itself and is further complicated by the absence of data on the volume and cost of different types of home care services and caregivers providing services to injured workers.”

Such was the opinion expressed by the RAND Center for Health and Safety in the Workplace. The center was asked by DWC to provide technical assistance in creating a fee schedule and related coverage policies for home health services.

A provision in California S.B. 863 requires the administrative director of the DWC to establish a fee schedule for home health care for injured workers, which typically include three types of services:

  • Skilled nursing and therapy services provided by home health agencies or other home care providers.
  • Assistance with personal care tasks such as bathing, grooming, dressing, and eating.
  • Chore services such as housework, shopping, and meal preparation that allow someone with impaired functional status to remain at home.

The law states that the DWC must adopt a fee schedule for those services not covered by Medicare, which only includes skilled care for a homebound individual intermittently or on a part-time basis. The schedule must establish fees and service provider requirements based on the rules used by the In-Home Supportive Services Program, a state program that provides supportive services necessary to allow disabled and elderly individuals to remain safely in their homes.

RAND recommends having standardized codes describing the type and volume of services provided. Also, “to ensure that workers receive needed services required by their work-related conditions and to reduce contention between payers and injured workers over what services are needed, there should be an independent patient needs assessment that considers the services required by the individual’s functional status and home environment,” the report said. “Family members should be allowed to provide attendant care services when they have the training to do so and there is appropriate financial accountability and oversight.”

The report includes three sets of recommendations. The first deals with policies and activities that should be undertaken despite any actions taken on the other two sets of recommendations.

The second set pertains to implementing a single, integrated fee schedule based on the Medicare, IHSS, and Office of Workers’ Compensation Program schedules. The OWCP covers federal workers and selected state workers’ comp programs. The fee schedule would be based on using the Medicare per visit rates for intermittent or part-time care, the IHSS hourly rates for unskilled attendant services, and the OWCP rates to fill the gap between the two.

“Because we are concerned by the complexities raised by this type of fee schedule and the adequacies of both the Medicare per visit allowances and the IHSS allowances, we also developed a third set of detailed recommendations based on implementing an OWCP-type fee schedule, at least with respect to skilled home health services that would not otherwise be covered under IHSS,” RAND said. “We believe that this fee schedule is more likely to accurately match the allowances with the services needed by injured workers, is less prone to payment disputes and potential abuse, and is administratively less complex. Unlike the Medicare or Medicaid fee schedules, it has policies that are tailored to a workers’ comp population, e.g., limiting coverage to services required by the work-related condition.”

Nancy Grover is the president of NMG Consulting and the Editor of Workers' Compensation Report, a publication of our parent company, LRP Publications. She can be reached at [email protected].

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