1.) Can home health agencies and SNF's be reimbursed for providing CLIA Waived Lab services?

Answer: The Clinical Laboratory Improvement Act (CLIA) of 1988 changed the way laboratories are certified and reimbursed by Medicare. CLIA waiver status is required for Physicians, suppliers and providers of Medicare services. Yes this would include home health agencies and SNF's. A provider of services to Medicare Part B beneficiaries with a valid CLIA Waiver Certificate may bill for CLIA Waived Lab Tests through their Part B Carrier.

2.) What labs are considered CLIA Waived?

Answer: The CLIA Waived Lab tests are specifically identified on the listing maintained by CMS. The most common tests performed by HHA and SNF providers include, blood glucose testing (including by finger stick method), prothrombine time(PTInr), glyco-hemoglobin (AIC), urinalysis (UA), complete blood count(CBC), fecal occult blood, sedimentation rate and thyroid profiles(TSH, T3 & T4).

3.) It seems that these lab services provided by HHA or SNF clinical staffs would be included in the HHRG or RUG payments. What reimbursements are available?

Answer: There are two components for laboratory reimbursement. One is the Technical Component and the other is the Administrative Component. HHA's and SNF's are involved in the Administrative Component, whereby they obtain specimens and monitor blood glucose levels under the supervision of a physician. They chart results and report them to the physician in conjunction with the physician's treatment of the patient / resident. The Home Health Agency Billing Manual Chapter 10, Section 90(D) specifically instructs home care agencies to bill these services to the Carrier on CMS-1500 and not to report these on the HHRG billing to the RHHI. In the case of SNF's it is true that all lab services for residents being reimbursed under Medicare Part A benefit are bundled, therefore the carrier is not to be billed. However, in SNF's it is common to have a significant census of residents with Medicare Part B benefits and whose SNF benefits are not reimbursed through Medicare Part A.

4.) My company is a for profit home health care agency. I hear that Federal Grant Monies are available for tele-monitoring services. Are grant monies only available to not-for-profit entities?

Answer: While its true that often Federal Grants are awarded to not-for-profit entities, we are currently in an environment where the federal government is looking to partner with the private sector (for-profit) and are making grant monies available to the private sector with the goal to improve the health care benefit to beneficiaries while searching for means to control the ever upward spiral of providing health care. Tele-Medicine is an area where these grants are currently available.