January 2022

Comprehensive Assessment

The Conditions of Participation, section 484.55 mandates that all patients receive a Comprehensive
Assessment. In this session, we will discuss what this means and how it compares and contrasts to
the Initial Assessment that is also provided.

The objectives for this session are to:

 Explain the timeframes and requirements of the Initial Assessment as well as the
Comprehensive Assessment.
 Understand the elements required in the Comprehensive Assessment.
 Understand which home health clinicians are responsible for completion of the
Comprehensive Assessment.

Each Medicare home health patient receives two types of assessments.

The Initial Assessment, which must be performed either within 48 hours of referral, within 48 hours
of the patient's return home or on the physician ordered start of care date. This initial assessment is
done to determine the patient's eligibility for services and, if used as the SOC visit, it also becomes
the first billable service for admission.

The Comprehensive Assessment must be completed in a timely manner, consistent with the
patient’s immediate needs and be no later than five calendar days after the start of care.

During both Assessments, the home health organization must verify the patient's eligibility for the
Medicare home health benefit including homebound status.

Typically, these assessments will likely be completed by the Registered Nurse. The regulations state:
A registered nurse must conduct an initial assessment visit to determine the immediate care and
support the needs of the patient.

When rehabilitation therapy service (speech language pathology, physical therapy, or occupational
therapy) is the only service ordered by the physician who is responsible for the home health plan of
care, and if the need for that service establishes program eligibility, the initial assessment visit may
be made by the appropriate rehabilitation skilled professional. These same rules regarding the
clinician completing the assessment hold true for the comprehensive assessment.

The comprehensive assessment is made up of several required components. However, we need to

understand that the comprehensive assessment is not the OASIS assessment by itself. While OASIS
may be included as part of a comprehensive assessment, the OASIS assessment cannot stand alone
as the comprehensive assessment. Another point to be made is the comprehensive assessment
must be unique and individualized to each patient’s needs. There should be no similarity from one
patient’s assessment to another.

The CoPs spell out the guidelines for completion quite clearly. First of all, the conditions clarify the
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fact that the comprehensive assessment must accurately reflect the patient's status, and must
include the following information:
 The patient’s current health, psychosocial, functional and cognitive status.
 The patient’s strengths, goals, and care preferences including information that may be used
to demonstrate the patient's progress toward achievement of the goals identified by the
patient and the measurable outcomes identified by the home health organization.
 The patient's medical, nursing, rehabilitative, social and discharge planning needs.
 The patient's continuing need for home care.
 A review of all medications the patient is currently using in order to identify any potential
adverse effects or drug reactions. This includes ineffective drug therapy, significant side
effects, significant drug interactions, duplicate drug therapy and noncompliance with drug
therapy.
 The comprehensive assessment must also include the patient’s primary caregiver(s), if any,
and other available supports, including their willingness and ability to provide care,
availability and schedules.
 The patient’s representative (if any).
 Incorporation of the current version of OASIS including clinical record items, demographics
and patient history, living arrangements, supportive assistance, sensory status,
integumentary status, respiratory status, elimination status, neuro/emotional/behavioral
status, ADLs, medications, equipment management, emergent care and data items collected
at inpatient facility admission or discharge.

The conditions continue with language related to updating the comprehensive assessment, which
has many similarities to OASIS requirements. Clinicians individualized findings during the assessment
should be clearly integrated into the OASIS document. The CoP’s state the comprehensive
assessment must be updated and revised (including the administration of the OASIS) as frequently
as the patient’s condition warrants due to a major decline or improvement in the patient’s health
status and/or during the last five days of every 60-day period beginning with the start-of-care date,
unless there is a
(i) Beneficiary elected transfer
(ii) Significant change in condition
(iii) Discharge and return to the same HHA during the 60-day episode

The comprehensive assessment also needs to be updated within 48 hours of the patient’s return to
the home from a hospital admission of 24-hours or more for any reason other than diagnostic tests,
or on the physician-ordered resumption date and at the time of discharge from Home Health
Services.

Although there is one clinician responsible for the completion of the comprehensive assessment,
collaboration is allowed. Only one clinician can take responsibility for the accurate completion of a
patient’s comprehensive assessment, however, that clinician can take into account the feedback of
others.

The clinician can elicit input from patients, caregivers, the physician, pharmacist, home health aides
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and other health care professionals to get a more complete assessment of the patient within the
allowed timeframe.

When collaboration occurs, the assessing clinician is responsible for considering available input from
these other sources and selecting the appropriate OASIS item response(s).