Course
Home Health Billing and Reimbursement
Course Highlights
- In this course, learners will review the home health billing and reimbursement components and learn how to apply them in caring for clients who receive home health care services.
- Learners will also review the steps of the home health billing cycle and the codes used in this billing cycle to learn how to implement these concepts in nursing practice.
- Finally, learners will review third-party payor reimbursement challenges and learn how to apply this knowledge to improve the nursing care of home health clients.
About
Contact Hours Awarded: 3
Course By:
Joanna Grayson
BSN, RN
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The following course content
Home health care enables qualified clients to receive skilled medical treatment in their homes, reducing healthcare costs. However, due to the increased number of clients receiving home health care, government regulations, and third-party payor restrictions, the billing and reimbursement process has become very convoluted and cumbersome for home health agencies (HHAs).
Home health care is a multi-billion-dollar industry that is growing exponentially not only due to the aging of America but also because private equity funds and large insurance companies are buying smaller, independent agencies and rolling them into larger, corporate home health agencies that demand higher profits.
Home health agencies are burdened with constantly training clinicians and billing professionals to help them keep abreast of changes in the industry that impact the HHAs’ bottom lines. Nurses need to understand the home health billing and reimbursement process to assist their HHA employers in maintaining financial stability, ensuring regulatory compliance, and delivering optimal care to clients.
Introduction
Home health care enables clients to receive skilled medical treatment in the comfort of their own homes, which helps reduce healthcare costs. However, home health care billing and reimbursement have become more convoluted due to the increase in the number of clients receiving home health care due to the aging of the population, government regulations, and third-party payor restrictions. For example, according to a McKinsey study, $265 billion worth of care services for Medicare fee-for-service and Medicare Advantage clients could pivot from traditional facilities to home care by 2025 (20). By the year 2030, one in five Americans will be older than 65 years of age, and 90% of the population above age 65 is expected to have one or more chronic diseases that require long-term treatment, many of which can be managed from home (9).
According to the Centers for Disease Control and Prevention (CDC), there are over ten thousand home health agencies (HHAs) in the United States, with roughly 85% of these being for-profit companies [4]. In 2020, over three million Americans received home healthcare services (4). In other reports, the home healthcare market was estimated at approximately $400 billion in 2023 and is expected to hit close to $700 billion in 2030, with a growth rate of roughly 8% between 2024 and 2030 (9). With the cost of hospital stays escalating, governments and health organizations endorse home health care as an alternative to expensive hospital stays, with some reports finding that home healthcare services reduce healthcare costs by 30% while decreasing client medical complications (9).
Neurological and mental health disorders accounted for the largest revenue share in 2023 the home health care industry (9). Clients who have diagnoses of stroke, Alzheimer’s disease, multiple sclerosis, Parkinson’s disease, and the like require home health services of physical and occupational therapies, speech therapy, and medication management. This population is growing exponentially, with the expected number of Americans with Alzheimer’s disease expected to rise to 13.8 million by 2060 in comparison to the 6.5 million people affected by the disorder in 2022 (9).
To accommodate the demand for home health care, large corporations have encroached on the market by purchasing HHAs. Private equity firms have taken advantage by buying smaller home healthcare agencies and consolidating them into large chains, driving down the competition of independent agencies (2).
The home health care billing process entails submitting claims to payors for reimbursement of services the client receives while receiving medical treatment and recovering at home. However, with the constant shifts affecting the industry, this process has become very cumbersome. Understanding the home health billing and reimbursement process enables nurses to assist HHAs in maintaining financial stability, ensuring regulatory compliance, and delivering effective care to clients.

Self-Quiz
Ask Yourself...
- Which factors are causing home health care billing and reimbursement to become more convoluted?
- How is the aging of America affecting the home healthcare market?
- Which health disorders account for the largest revenue share in the home healthcare industry, and why?
- Which types of organizations are encroaching on the home healthcare market, and how are they affecting the market?
Initial Steps of the Home Health Care Billing Cycle
HHAs are tasked with delivering healthcare services to clients and billing and collecting payments. The healthcare billing and reimbursement paradigm comprises several entities.
These entities are (16):
- Home health agencies: These agencies provide skilled nursing care, therapy services, support for activities of daily living, and other healthcare services to clients in their homes.
- Clients: The client, or patient, receives the home health services, and their eligibility and coverage are important components of the billing process.
- Payors (also spelled “payers”): These entities reimburse home health agencies for the services rendered to the client.
- Clinicians: Healthcare staff that delivers treatments to clients in their homes includes nurses, nurse assistants or aides, therapists, and other healthcare professionals.
- Billing staff: These staff members are trained to submit claims, track payments, and maintain the revenue cycle during the billing process.
The billing process begins before the home health clinical staff visits the client’s home to deliver treatment. The intake process involves collecting the client’s demographic and medical diagnosis information, verifying the client’s insurance coverage and benefits, determining the client’s eligibility for home healthcare services, and obtaining required pre-authorizations from the payor (16). The intake personnel must collect data thoroughly to ensure that the client’s payor does not deny claims and delay payments (16).
HHAs train their clinicians to use precise, detailed documentation to facilitate payment. This documentation includes detailed visit notes, completed Outcome and Assessment Information Set (OASIS) assessments for Medicare clients, physician orders and care plans, and any changes to the client’s condition or treatment (16). Client health records provide a clinical plan of care, ensure an audit-ready foundation for claims, and facilitate payor payment.

Self-Quiz
Ask Yourself...
- Which type of services do HHAs provide to clients?
- What is the payor’s role in the home healthcare billing cycle?
- What is the role of billing staff in the home health care billing cycle?
- When does the home health care billing process begin?
Billing Codes Used in Home Health Care
Once the initial steps of the billing cycle are completed and the clinical services the client receives are documented, the services are translated into billable codes. Home health billing codes are standardized alphanumeric designations that report medical services, procedures, and supplies to insurance payors, including Medicare and Medicaid.
The types of codes used in home health billing are (16,18):
- International Classification of Diseases, Tenth Edition, Clinical Modification (ICD-10-CM)
- Healthcare Common Procedure Coding System Codes (HCPCS)
- Revenue Codes
These three codes provide a comprehensive picture of the care and services HHAs provide to clients. HCPCS are procedure codes that offer specific details about the services rendered, and these form the foundation of home health billing. HCPCS includes Level I: current procedural terminology (CPT) codes and Level II: alphanumeric codes. Level II HCPCS codes report services, equipment, and supplies not covered by CPT codes (18). Simply put, HCPCS codes detail the exact procedures, services, and supplies provided to the client (18).
As detailed in the table, 10 HCPCS codes are most commonly used in home health care.
Most Common 10 HCPCS Codes (18)
Code |
Description |
G0299 | Direct skilled nursing services an RN provides—assessment, care planning, wound care, etc.—in the home health or hospice setting are billed in 15-minute increments. |
G0300 | Direct skilled nursing services provided by an LPN—similar to RN services listed in G0299—in the home health or hospice setting are billed in 15-minute increments. |
G0151 | A physical therapist provides services that aim to improve client strength, mobility, and function in the home health or hospice setting. These services are billed in 15-minute increments. |
G0152 | Services provided by an occupational therapist that aim to improve client activities of daily living in the home health or hospice setting are billed in 15-minute increments. |
G0153 | Services provided by a speech-language pathologist that aim to address communication and swallowing disorders in the home health or hospice setting are billed in 15-minute increments. |
G0155 | A clinical social worker provides services that address client social and emotional factors that affect home health or hospice treatment. These services are billed in 15-minute increments. |
G0156 | A home health/hospice aide provides services that address client personal care in the home health or hospice setting. These services are billed in 15-minute increments. |
G0162 | Skilled services provided by an RN for management and evaluation of the client’s care plan billed in 15-minute increments |
G0493 | Skilled services provided by an RN for the assessment of a client when changes in the client’s condition require evaluation of treatments billed in 15-minute increments |
G5001 | Location code that specifies home health or hospice care that is provided in the client’s home or residence |
HCPCS codes provide specific details, while revenue codes use only three digits to categorize the type of service provided in a general sense (18). Revenue codes group services into broader categories for easier processing and reporting. The table displays the common revenue codes used in home health.
Most Common Revenue Codes (18).
Description and Subcodes |
0023—Home Health Resource Groups (HHRGs) under the Home Health Prospective Payment System (HHPPS) |
027X–Medical/Surgical Supplies 0270: General Classification 0271: Nonsterile Supply 0272: Sterile Supply 0273: Take Home Supply 0274: Prosthetic/Orthotic Device 0279: Other Supplies/Devices |
042X—Physical Therapy 0420: General Classification 0421: Visit Charge 0424: Evaluation or Re-evaluation |
043X—Occupational Therapy 0430: General Classification 0431: Visit Charge 0434: Evaluation or Re-evaluation |
044X—Speech-Language Pathology 0440: General Classification 0441: Visit Charge 0444: Evaluation or Re-evaluation |
055X—Skilled Nursing 0550: General Classification 0551: Visit Charge 0559: Other Skilled Nursing |
056X—Medical Social Services 0560: General Classification 0561: Visit Charge |
057X—Home Health Aide 0570: General Classification 0571: Visit Charge 0579: Other Home Health Aide |
0636—Drugs Requiring Detailed Coding Used for reporting drugs that require specific identification |
0771—Vaccine Administration Used for reporting vaccine administration in the home healthcare setting |
It is essential for nurses and billing specialists to maintain consistency in the use of revenue codes across similar services, use the most specific revenue code available for the service provided, ensure that clinical documentation accurately supports each revenue code, promptly implement new revenue codes, and attend regular training regarding revenue codes to ensure that their HHA is receiving appropriate reimbursement (18).
ICD-10-CM codes document client diagnoses and their medical necessity, assist nurses in developing appropriate care plans, and provide data for reporting diseases, injuries, and health conditions that affect population health (18). These codes justify the medical necessity for services. When using ICD-10-CM codes, nurses should keep these aspects in mind: use the most specific code possible that aligns with the client’s condition, list the primary diagnosis first followed by secondary diagnoses, avoid using unspecified codes, code for support services, and regularly update codes based on the client’s condition changes (18).
The most common ICD-10-CM codes used in home health are displayed in the table.
Most Common ICD-10-CM Codes (18).
Code |
Description |
110 | Essential (primary) hypertension |
E11.9 | Type 2 diabetes mellitus without complications |
150.9 | Heart failure, unspecified |
M17.9 | Osteoarthritis of the knee, unspecified |
J44.9 | Chronic obstructive pulmonary disease, unspecified |
163.9 | Cerebral infarction, unspecified |
Z96.641 | Presence of right artificial hip joint |
S72.001D | Fracture of unspecified part of neck of right femur, subsequent encounter for closed fracture with routine healing |
L89.604 | Pressure ulcer of unspecified heel, stage 4 |
Z48.89 | Encounter for other specified surgical aftercare |
Nurses should implement these steps when utilizing ICD-10-CM codes (18):
- Ensure clinical documentation supports all coded diagnoses.
- Use combination codes that include the underlying condition and associated complications.
- Include codes for chronic conditions, even if these conditions are not the focus of the current treatment.
- Include external cause codes when appropriate.
- Don’t code separately for conditions that are integral to a disease process.
- Keep abreast of annual coding guidelines and changes.
- Maintain communication with coding staff to ensure accuracy.
Nurses in the home health care setting become proficient over time at combining these three types of billing codes into a comprehensive framework that benefits their clients and their HHA.

Self-Quiz
Ask Yourself...
- What are the components of home health billing codes, and what is their purpose?
- How do HCPCS and revenue codes differ?
- Which steps can clinicians and billing specialists take when using revenue codes to ensure their HHA receives appropriate reimbursement?
- What are the most common ICD-10-CM codes used in home health care, and which medical conditions do they represent?
Next Steps in the Home Health Care Billing Cycle
After the claims are prepared, the billing specialist submits them according to filing deadlines to the appropriate payors through an electronic clearinghouse or direct payor portal. First, the specialist ensures that the claims meet the format requirements and other specifications and may utilize billing software products to help minimize clerical errors and assist HHAs in maximizing reimbursements.
As the payors receive the payments, they are posted to the client accounts by matching payments to submitted claims, identifying and addressing any discrepancies, and applying contractual adjustments (16).
Even though the billing specialist submits perfectly prepared claims, payors often deny them [16]. Therefore, the billing specialist needs to regularly track the status of claims, promptly address denials, supply supporting documentation when incorrect denials occur, and resubmit corrected claims as necessary (16).

Self-Quiz
Ask Yourself...
- Which factors do billing specialists adhere to when submitting client claims to payors?
- What steps do payors take to post payments to client accounts?
- Which type of products can help minimize clerical errors on behalf of HHAs when submitting claims to payors?
- What steps can the billing specialist take to ensure the payor accepts client claims?
Medicare Home Health Care Services and Billing
Since 2001, Medicare’s Home Health Prospective Payment System (HH PPS) has been the payor to HHAs for home health services, and it pays a predetermined amount for each episode of care that is adjusted for case-mix, service use, geographic variation in wages, and other factors that affect resource use (14). Additionally, Medicare is the largest payor for home healthcare services. It supports clients who require skilled nursing care intermittently or have an ongoing need for occupational therapy due to being unable to leave their homes without considerable effort (10,12).
Medicare does not require a deductible or copayments for home care services, but they limit payment to a predetermined amount for 30 days. There is no limit to the number of days that a client is entitled to home care services, but they must qualify for the services (12).
The U.S. Center for Medicare & Medicaid Services (CMS) covers two categories of health services that can be reimbursed: Medicare Part A (hospital insurance) and Medicare Part B (medical insurance) (10). Part A services are available to those clients who are confined to their homes due to the advice of a qualified healthcare provider.
These services include skilled nursing, physical therapy, medical social services, speech and language pathology, occupational therapy, and home health aide services (20). Clients can be classified as homebound if they are diagnosed with a condition, injury, or illness requiring them to rely on another person to leave their home. These clients must receive an in-person visit from a medical professional, be under a plan of care prepared by a certified physician, and require intermittent skilled nursing, physical therapy, or speech-language pathology services (10).
According to Medicare, “homebound” means (10):
- Due to illness or injury, the client is unable to leave home without the assistance of a cane, wheelchair, walker, crutches, special transportation, or another person.
- The healthcare provider has advised against the client leaving home due to their illness or injury.
- It takes significant effort for the client to leave their home due to their illness or injury.
Part B services provided by CMS are for clients not confined to home but still require services and supplies to treat their medical conditions. Preventative services for early detection of illness are provided under Part B.
Medicare covers the following home care services (10):
- Wound care for pressure injuries or surgical wounds
- Intravenous or nutrition therapy
- Injections
- Client and caregiver education
- Monitoring serious illness or unstable health status
- Occupational and physical therapy
- Speech-language pathology services
- Medical social services
- Home health care aide services
- Injectable osteoporosis medications for women
- Medical supplies for home use
- Disposable harmful pressure wound therapy devices
- Durable medical equipment
Medicare does not pay for round-the-clock care (24/7), home meal delivery, homemaker services (shopping/cleaning) unrelated to the client’s care plan, or assistance with ADLs if this is the only care the client requires (10). Any care that exceeds part-time, intermittent care makes clients ineligible for Medicare.
To qualify for home healthcare services, the client must be assessed by a healthcare provider in person; this healthcare provider must order the care, and a Medicare-certified HHA must provide the care (10). To receive CMS reimbursement, HHAs must consistently provide all documentation and consolidated billing for Part A and Part B services to their Medicare Administrative Contractor (MAC). Quarterly and annual documentation that needs to be provided includes invoice numbers, HCPCS codes, client names, descriptions of services, dates of services, and charges (20).
As of January 2022, HHAs must submit a notice of admission (NOA) to their MAC within five days of starting a client’s home health services (11). This establishes the primary HHA and alerts the claims processing system that a 30-day home health care period has begun. The NOA is submitted by the HHA when the practitioner signs the plan of care. A non-time submission fee is assessed if this requirement is not met. The NOA may be submitted via mail, electronic data interchange (EDI), or the Direct Data Entry system (20).
In 2021, the Patient-Driven Groupings Model (PDGM) reduced payment periods from 60-day episodes to 30-day episodes to remove unnecessary client services and implement a value-based approach to client care (7,20). This move encouraged HHAs to increase care coordination and client oversight.
In 2022, Medicare started calculating home health reimbursements using the Home Health Value-Based Purchasing (HHVBP) model, which encourages quality of care rather than quantity (3,20). Under this model, HHAs receive points based on their achievement level relative to baseline threshold values or improvement relative to their baseline performance (3).

Self-Quiz
Ask Yourself...
- Which factors does Medicare’s HH PPS consider when issuing payments to HHAs?
- What are the requirements for a client to be considered for Medicare home health care services?
- Which services does Medicare not pay for?
- What is a notice of admission (NOA), and when must it be filed?
Medicaid Home Health Care Services and Billing
Medicaid pays for home care in all 50 states. It enables older clients to remain at home without having to relocate to a residential care facility (nursing home), enabling these individuals to maintain their independence while saving the government money. Medicaid focuses on consumer-directed care, participant-directed care, cash and counseling, and self-directed care that permits the care recipients to hire their relatives as paid caregivers (1).
For example, adult children can be hired to care for their aging parents, or an able spouse can care for the client. Medicaid permits the term “home care” to extend to the home of a friend or relative, an adult foster care home, or an assisted living facility. The individual state and Medicaid programs determine the exact setting eligible for assistance.
Home health care services are available via the client’s state Medicaid plan. Still, they can also be offered through Home and Community Based Services (HCBS) Medicaid Waivers or Section 115 demonstrated Waivers. The states must make home health benefits available to needy clients via the regular state Medicaid program called “original Medicaid” and “classic Medicaid.” Many states also offer personal care assistance with activities of daily living (ADLs) and instrumental activities of daily living (IADLs) in the home, which is not federally mandated (1).
States offer an original Medicaid plan, but Community First Choice (CFC) also covers ADLs and IADLs as implemented by the Affordable Care Act (ACA). Alaska, California, Connecticut, Maryland, Montana, New York, Oregon, Texas, and Washington offer CFC, where a personal care assistant helps clients with grooming, mobility, toileting, preparing meals, and light housekeeping so the older adults can remain at home (1).
HCBS Section 1915(i) permits skilled nursing services, adult day health care, respite care, and home modifications without requiring clients to demonstrate their need for nursing home care. Clients with Alzheimer’s disease and those who are frail typically benefit from this offering (1). There is no waiting list for regular Medicaid home care services, but clients must meet the eligibility criteria.
Section 1915(c) Waivers of HCBS offer a nursing home level of care to individuals at risk for institutionalization. These Waiver programs provide more in-home services than regular Medicaid plans, including adult day care, companionship care, assistance with ADLs, personal emergency response systems, and durable medical equipment. These Waivers are not entitlement programs, but they require establishing eligibility and being placed on a waiting list in most cases (1).
Clients are placed into eligibility groups for Medicaid services where their income and assets are considered. Typically, most states limit the recipient’s income to either 100% of the Federal Poverty Level (FPL) or 100% of the Supplemental Security Income (SSI)/Federal Benefit Rate (FBR). States that use 100% of the FPL as the income limit allow a single applicant up to $1,225/month in income. States that use 100% SSI limit the client’s income to $943/month, and assets are limited to $2,000. Clients can still qualify for Medicaid if they exceed these limits since assets like a home, household furnishings, cars, and marital jewelry are exempt (1).
Nurses should be aware that not all HHAs accept Medicaid clients, so Medicaid clients are permitted to hire their chosen caregivers, including friends and relatives, to help care for them. How much Medicare pays for home care services depends on the individual state and the Medicaid program in which the client is enrolled. Some programs cover the cost of a personal care assistant several hours a day for a few days a week, adult day care a few days a week, or respite care a couple of times a month (1).

Self-Quiz
Ask Yourself...
- On which factors does Medicaid focus?
- What is CFC, and how does it benefit Medicaid clients?
- What client income limits are used to determine client eligibility for Medicaid?
- Why does Medicaid reimburse clients when friends and relatives serve as the client’s caregivers?
CMS Alternative Payment Models
CMS Innovation Center tests alternative payment models (APMs) to reward healthcare providers for delivering coordinated, high-quality care. APMs can be applied to communities (rural areas), provider types (primary care physicians), health conditions (diabetes mellitus), and health services (joint replacement surgery) (5). APMs can also focus on specific ways to receive Medicare coverage, such as Medicare Advantage and Medicare Part D. The models reward healthcare providers for focusing on quality and value versus the number of clients they treat or services they provide.
One CMS APM uses a pre-payment, or capitation, method where healthcare providers and organizations receive a predictable, upfront, set amount of money to cover the predicted cost of some healthcare services for a specific client over a particular time (5,6).
Healthcare providers and organizations participating in the capitation model are paid a set amount for each client for certain services received over a predetermined period. The capitated payment is based on characteristics and health conditions that predict whether a client will have lower or higher healthcare costs than the average Medicare client, and the collection of these characteristics and health conditions is called a risk score (6). CMS states that this payment model holds healthcare providers and organizations accountable for healthcare costs and client outcomes by allowing healthcare providers to focus on client care while avoiding high-cost treatments and procedures (5,6).
The pre-payment method also enables healthcare providers to deliver services like preventative care and social services while spending more time with clients to address their holistic needs instead of focusing on providing care to a high volume of clients and thus comprising the clients’ quality of care [5,6]. CMS also claims the pre-payment method is effective because it provides healthcare providers with stable funding. For example, during the COVID-19 pandemic, primary care physicians were challenged to keep their practices open. Many clients did not want to visit doctors’ offices for fear of contracting the virus, so it was difficult for physicians to maintain operating costs. CMS claims that the pre-payment system allowed physicians to remain in business (6).
However, dissenters of CMS APMs have a different perspective. Since we live in a society where individuals are living longer, the home healthcare industry impacts older adults on a significant level (2). Traditionally, Medicare pays for healthcare services and administers the program, which enables older clients to seek care from the provider of their choice. Medicare pays the healthcare provider’s fee when the claim is submitted.
Conversely, Medicare Advantage (MA) is paid by Medicare but is operated by private health insurance companies, making MA a privatized form of Medicare. Opposers of CMS APMs state that the evidence shows that capitated pre-payments and privatized senior care have led to higher costs for Medicare that result in a drain on the organization’s trust fund, higher profits for insurance companies, and reduced quality of client care due to the narrowing of client healthcare provider choices and preauthorization for treatment that can be denied (2).
Large health insurance companies that own Medicare Advantage plans, such as Humana, CVS/Aetna, and United Health Group, have encroached on the home healthcare market by purchasing HHAs. Private equity firms have taken advantage by buying smaller HHAs and consolidating them into large home healthcare chains, driving down the competition of independent agencies (2). Since plans receive more money for higher-risk clients, the insurance companies inflate client risk scores, which is easy for them to do since many also own risk assessment companies (2). This creates a system where conflict of interest is supported, and Medicare is overcharged (2).
Medicare Advantage costs substantially more per client, yet CMS continues to market the program as more cost-effective than traditional fee-for-service Medicare. The Medicare Payment Advisory Commission (MedPAC), which is nonpartisan, estimates that the upcoding by MA plans makes members appear sicker than they are and costs CMS, and thus the tax-paying American public, over 100 percent of traditional Medicare (2).
MedPAC found that in 2020, Medicare spent $1,538 more per beneficiary in MA plans than it would have spent for the same clients had they received traditional Medicare support, resulting in $12 billion in overpayments (2). Taxpayers also shoulder MA bonus payments for quality, referred to as “star inflation” because of the number of stars that correlate to quality ratings, which can be used to increase plan profits, unlike other rebates that MA receives, which must be used to reduce premiums and provide client benefits (2).
According to research findings, MA beneficiaries are treated by lower-quality providers in HHAs and skilled nursing facilities. They have less access to home health care, shorter periods of care when they qualify for home health care and worse outcomes than traditional Medicare beneficiaries (2).

Self-Quiz
Ask Yourself...
- What is the purpose of CMS APMs?
- Which services does the CMS pre-payment model enable healthcare providers to offer clients?
- What is the conflict of interest between insurance companies and risk assessment companies?
- What is the “star inflation” of Medicare Advantage, and how does it affect Americans?
Home Health Value-Based Purchasing Model
In 2016, the CMS Innovation Center initiated a new model called the Home Health Value-Based Purchasing (HHVBP) model and randomly selected the following states to trial the program in their HHAs, which was a mandatory requirement: Arizona, Florida, Iowa, Maryland, Massachusetts, Nebraska, North Carolina, Tennessee, and Washington (8,14,17). The goal of the HHVBP model was to provide financial incentives to HHAs that improved the quality of care they delivered (8,14,17). The model was trialed for six years, and in 2023, HHVBP was implemented for all Medicare-certified HHAs in the United States.
HHAs are assigned to a cohort based on their size (small or large) and receive a total performance score (TPS), a composite score of its quality achievement and improvement, that is based on its claims, OASIS assessments, and Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) surveys (17).
When HHAs don’t fully utilize resources like Interim Performance Report (IPR) from CMS via Internet Quality Improvement and Evaluation Systems (iQIES) that shows an HHA how it performed to other agencies in its cohort, its reimbursement under HHVBP is negatively impacted (17).Conversely, the HHA’s TPS can improve when the HHA outperforms other agencies and does better than its baseline median. HHAs can improve their scores by prioritizing measures with a higher TPS weight, such as the hospitalization measure. Additionally, nurses can use their observation, interview, and collaboration skills to improve their data collection and, thus, OASIS assessments, which can also improve TPS (17).
TPS values are steadily increasing, making it difficult for HHAs to be on the positive side of the reimbursement impact equation. HHAs must not rest on their laurels of past accomplishments but constantly push forward for continuous improvement. HHAs can improve scores by evaluating low-performance areas and recognizing where improvements will make the most significant difference. Taking HHCAHPS scores and client comments seriously can pinpoint where HHAs are falling short and bridge the gap between existing and future scores.

Self-Quiz
Ask Yourself...
- What was the goal of the HHVBP when the trial was initiated in 2016?
- What is the total performance score, and which factors is it based?
- Which factors can negatively impact an HHA’s performance score?
- Which actions can improve an HHA’s performance score?
PDGM Audits
In 2020, Medicare’s Patient-Driven Groupings Model (PDGM) eliminated therapy as a direct determinant of HHAs’ reimbursements (Plummer). Instead, Medicare links HHA reimbursement to clients’ medical conditions to support Medicare’s value-based payment model. Research has found that PDGM increases payments to rural and facility-based HHAs and HHAs that serve non-white, dual-eligible, and seriously ill clients.
Payments increased for HHAs that scored high on quality surveys, but payments decreased for those HHAs with higher outcome and process quality scores (13). Rural and larger HHAs, as well as those with more seriously ill, younger, and non-white clients, received higher residual payment increases under PDGM (13).
PDGM audits ensure that HHAs remain compliant with CMS regulations, particularly regarding their home health ICD-10 coding and OASIS practices (7,19). The audits identify areas where HHAs can improve and highlight potential vulnerabilities and risks.
Auditors review HHAs’ primary and comorbidity codes and OASIS assessments to highlight potential reimbursement opportunities or at-risk reimbursement penalties. This can save the HHAs from incurring CMS penalties while improving quality and maximizing revenue. During the audits, the auditors review primary diagnosis codes to ensure that the client’s medical record supports them, comorbidity adjustment opportunities that have been missed, and key M items on the OASIS to assess the impact of coding adjustments on the client’s case-mix weight (19).
To prepare for the audits, HHAs can train and certify staff members who code and submit OASIS or outsource these tasks to a qualified specialist.

Self-Quiz
Ask Yourself...
- How does Medicare support its value-based payment model in terms of reimbursement?
- Which type of HHAs receive increased payments from Medicare’s PDGM?
- Which HHAs received higher residual payment increases under PDGM?
- Which factors do PDGM auditors focus on during their audits of HHAs?
Home Health Agency Billing Challenges
Several factors can negatively impact home healthcare billing and reimbursement. When nurses understand these issues, they can help their HHA run more smoothly.
These HHA billing challenges include (15,16):
- Prior authorization. If the prior authorization process is not followed, patient acceptance and care delivery can be delayed, which can decrease revenue.
- Coding complexities. In-depth knowledge of ICD-10-CM, HCPCS, revenue codes, and home health coding guidelines requires detailed expertise and regular staff training.
- Deadline adherence. Not adhering to payor deadlines can negatively impact the agency’s cash flow.
- Regulatory compliance. Since the home health industry is heavily regulated, it is essential to stay compliant with Medicare regulations, state Medicaid mandates, and ever-changing insurance policies.
- Documentation accuracy. Incorrect and incomplete documentation can lead to denials and reduced payments.
- Agency audits. PDGM reviews are comprehensive audits of home health coding and OASIS practices. These audits ensure compliance with CMS regulations, improved client care, and maximum reimbursement.
Steps to combat these billing challenges are (15,19):
- Identify the correct payor at intake. When HHA personnel incorrectly identify the client’s payor at intake, claims can be rejected, which leads to lost revenue. Providing ongoing staff training and assigning a trained staff person to delineate the client’s payor in the client’s electronic health record (EHR) can prevent issues.
- Track unbilled claims. Implementing a tracking system that exposes claims awaiting submission due to incomplete clinical tasks (missing care plans, incomplete OASIS notes, etc.) can yield sizable revenue for HHAs. Managers should conduct daily reviews and hold staff accountable for completing the gaps in the claims to facilitate reimbursement.
- Understand payors’ claim payment timeframes. Managing the agency’s expenses will be difficult if the billing professional does not understand and track the payment timeframes for claims, which differ for each payor entity. For example, Medicare claims pay within 14 to 30 days after receiving a claim, but rejection of the claim can further delay payment. The billing professional can create a chart delineating each payor’s reimbursement timeframe to ensure the agency maintains positive cash flow.
- Track expiring authorizations. Most home health agencies know how to secure prior authorizations but fail to secure additional ones when the initial ones expire. Tracking authorizations to ensure that they do not expire can prevent revenue loss.
- Prevent enrollment and contract challenges with commercial insurers. When a commercial insurer does not have the home health agency’s 1099 tax form or national provider identifier (NPI) number on file, payments can be significantly delayed. Ensuring that commercial insurers have all required documentation from the HHA can prevent roadblocks to reimbursement.
- Implement regular staff training. Training billing specialists and clinicians on documentation measures, regulatory updates, and coding changes can improve compliance and performance.
- Maintain payor relationships. Maintaining professional and supportive relationships with payors can improve efficiency by gaining early insight into policy changes.
- Utilize robust technology, data analytics, and quality assurance. Advanced EHR and billing software can improve eligibility verification, claims submissions, and documentation. Data analytics can help identify trends and track performance. Quality assurance pinpoints areas for improvement and maintains compliance with payor regulations.

Self-Quiz
Ask Yourself...
- Why is accurate documentation necessary in HHAs?
- What benefit does spending resources to track unbilled claims offer to HHAs?
- Why can tracking expiring authorizations prevent HHA revenue loss?
- What is the benefit of regularly training HHA staff?
The Future of Home Health Care Billing
The future of home health billing is affected by telehealth integration, artificial intelligence, machine learning, data sharing, and client financial responsibility. Particularly since COVID-19, telehealth has become increasingly popular in healthcare, including home healthcare. Home health agencies must adhere to regulations surrounding this healthcare delivery model and adapt their billing practices accordingly.
Home health billing is evolving from reactive to predictive due to innovative technology, which requires home health agencies to understand and integrate this technology. Data sharing among healthcare providers, payors, and clients will help improve billing processes and reduce errors. With clients becoming more concerned about high-deductible health plans, home health billing personnel will become an increasingly integral part of assisting and supporting clients.

Self-Quiz
Ask Yourself...
- Which factors affect the future of home health care billing?
- What is causing HHA billing to move from reactive to predictive methods?
- Which steps can HHAs take to reduce billing errors?
- Which future aspect of home health care is concerning to clients?
Conclusion
The aging of the American population has given rise to the necessity of home health care that permits clients to remain in their homes while managing or recovering from an illness that would otherwise be more expensive if treated in the hospital. Independent HHAs are becoming institutions of the past since large hospital corporations and private equity funds are purchasing and consolidating these smaller agencies to expand their organizations’ profits.
Due to government regulations and third-party payor restrictions, the billing and reimbursement of HHA services have become very convoluted. Because of this, nurses play an essential role in assisting HHAs in maximizing reimbursements by understanding home health care billing, documenting appropriately, and delivering exceptional client care that reduces costly hospital admissions.

Self-Quiz
Ask Yourself...
- What is involved in the initial intake process of a home health care client?
- Why must the HHA intake personnel thoroughly collect data when onboarding a new client?
- Which documentation factors are essential for clinicians to ensure proper billing and reimbursement of HHA clients?
- What are the three types of codes used in home health billing, and how do they differ?
- What are the 10 most common HCPCS codes used in home health billing?
- Which clinicians are included in the 10 most common HCPCS home health billing codes?
- What are the most common revenue codes used in home health billing?
- Which aspects should nurses consider when assigning ICD-10-CM codes to home healthcare clients?
- What is the significant difference between Medicare Part A and Medicare Part B?
- Which clients qualify for Medicare Part A, and which home health care services do they receive?
- What criteria does Medicare use to determine if a client is homebound?
- Which clients qualify for Medicare Part B, and which home health care services do they receive?
- How do HHAs receive reimbursement from Medicare?
- Which information needs to be provided in the quarterly and annual documentation to Medicare by HHAs to receive reimbursement?
- How does Medicare define the term “home care”?
- Which Medicaid clients benefit most from HCBS Section 1915(i)?
- What is the purpose of Section 1915(c) Waivers of HCBS, and who do they benefit?
- Which assets may be considered exempt when a client exceeds Medicaid allotted limits?
- What is capitation, and how does CMS utilize it?
- What are the benefits of capitation according to CMS?
- What is Medicare Advantage, and how does it work?
- MedPAC has determined that Medicare Advantage costs the American public what percentage amount of traditional Medicare?
- How can nurses help their HHA improve its HHVBP TPS?
- How can taking HHCAHPS scores and client comments help HHAs improve their HHVBP TPS?
- How can HHAs effectively prepare for PDGM audits?
References + Disclaimer
- American Council on Aging. (2024). Medicaid and home health care and non-medical, in-home care. Retrieved from https://www.medicaidplanningassistance.org/in-home-care/.
- Applebaum, E., Batt, R., Curchin, E. (2023). Profiting at the expense of seniors: The financialization of home health care. Retrieved from https://cepr.net/report/profiting-at-the-expense-of-seniors-the-financialization-of-home-health-care/.
- Bono, C. (2021). A quick breakdown of the home health value-based purchasing model. Retrieved from https://www.healthrecoverysolutions.com/blog/a-quick-breakdown-of-the-home-health-value-based-purchasing-model.
- Centers for Disease Control and Prevention (CDC). (2024). Home health care. Retrieved from https://www.cdc.gov/nchs/fastats/home-health-care.htm.
- Centers for Medicare and Medicaid Services (CMS). (2023). Alternative payment models (APMs). Retrieved from https://www.cms.gov/priorities/innovation/key-concepts/alternative-payment-models-apms.
- Centers for Medicare and Medicaid Services (CMS). (2024). Capitation and pre-payment. Retrieved from https://www.cms.gov/priorities/innovation/key-concepts/capitation-and-pre-payment.
- Centers for Medicare and Medicaid Services (CMS). (2024). Home health PPS. Retrieved from https://www.cms.gov/medicare/payment/prospective-payment-systems/home-health.
- Centers for Medicare and Medicaid Services (CMS). (2024). Home health value-based purchasing model. Retrieved from https://www.cms.gov/priorities/innovation/innovation-models/home-health-value-based-purchasing-model.
- Grand View Research. (2024). Home healthcare market size, share & trends analysis report by component (equipment, services), by indication (cardiovascular disorder & hypertension, diabetes & kidney disorders), by region, and segment forecasts, 2024-2030. Retrieved from https://www.grandviewresearch.com/industry-analysis/home-healthcare-industry#.
- Medicare.gov. (n.d.). Home health services. Retrieved from https://www.medicare.gov/coverage/home-health-services.
- Medicare Learning Network (MLN). (2021). Home health prospective payment system. Retrieved from https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/MLN006816_2020_05_Home_Health_PPS_Booklet_Final.pdf.
- National Association for Home Care and Hospice (NAHC). (2024). Medicare is the largest payer for home health services. Retrieved from https://nahc.org/home-health-providers/.
- Plummer, E., Wempe, W.F. (2021). Home health agencies: Empirical evidence on the patient-driven groupings model’s expected effects on agency reimbursements. Home Health Care Management & Practice, 33(3), 183-192. https://journals.sagepub.com/doi/10.1177/1084822321990382
- Pozniak, A., Lammers, E., Mukhopadhyay, P. Cogan, C., Ding, Z., Goyat, R., Hanslits, K., Ji, N., Jin, Y., Repeck, K., Schrager, J., Young, E. Turenne, M. (2022). Association of the Home Health Value-Based Purchasing Model with quality, utilization, and Medicare payments after the first 5 years. JAMA Health Forum, 3(9), e222723. https://jamanetwork.com/journals/jama-health-forum/fullarticle/2796639
- SimiTree (2024). 5 common pitfalls leading to home health agency failure. Retrieved from https://simitreehc.com/simitree-blog/5-common-pitfalls-leading-to-home-health-agency-failure/.
- SimiTree (2024). Complete guide to home health billing. Retrieved from https://simitreehc.com/simitree-blog/complete-guide-to-home-health-billing/.
- SimiTree (2024). Home health VBP: Lessons learned from year one. Retrieved from https://simitreehc.com/simitree-blog/home-health-vbp-lessons-learned-from-year-one/.
- SimiTree (2024). Overview of home healthcare billing codes. Retrieved from https://simitreehc.com/simitree-blog/overview-of-home-health-billing-codes/.
- SimiTree (2023). PDGM Audits FAQ: What to expect from audits for home health professionals. Retrieved from https://simitreehc.com/simitree-blog/pdgm-audits-faq-what-to-expect-from-audits-for-home-health-professionals/.
- Wilcox-Lee, C. (2024). Home health reimbursement: An up-to-date guide. Retrieved from https://www.healthrecoverysolutions.com/blog/home-health-reimbursement-an-up-to-date-guide.
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