Initial Visit and SOC Comprehensive Assessment – not the same thing!

In News by Sarah Bacon3 Comments

Due to the COVID-19 Public Health Emergency(PHE), CMS has waived the Home Health Condition of Participation under 42 CFR § 484.55(a) regarding the initial assessment:  This change allows home health agencies to perform initial assessments and determine patients’ homebound status remotely or by record review.

However, the initial assessment visit is NOT the same as the Start of Care comprehensive assessment visit – even though both are typically done at the first visit in the home.

The initial assessment visit is required to determine the patient’s immediate care and support needs, and the patient’s eligibility for coverage under the Medicare home health benefit:  1) is the patient homebound? 2) is the patient under the care of a physician? 3) is the patient in need of skilled services? 4) has the patient had a face-to-face encounter with a medical provider as mandated by the Affordable Care Act?

The initial assessment visit must be done within 48 hours of the patient’s referral to home care or return home from the inpatient facility, or on the physician-ordered start of care date.  This waiver for the COVID-19 PHE allows the agency to carry out the initial assessment via phone call to the patient or by medical record review instead of making an actual in-person to the patient’s home.  This determination must still be done within the 48 hours following referral or return home but does not require a home visit within that time period.

The Start of Care (SOC) comprehensive assessment is the required in-person clinical assessment of the patient’s physical, functional, mental, psychosocial, and cognitive status to identify the needs of the patient and caregiver that will be addressed by the home health agency’s services.  This comprehensive assessment at SOC includes the collection of OASIS data.  This comprehensive assessment must be completed within a specific time frame after the SOC date (first reimbursable visit). Prior to the COVID-19 PHE, agencies had a 5 day window to complete data collection for the SOC comprehensive assessment – under the COVID-19 PHE changes, that time frame has been extended to 30 days following the SOC date.

Most of the time, the agency sends the clinician (nurse, PT or SLP) to “admit the patient” – the clinician evaluates the patient to make sure they meet the requirements for home care services, explains and signs the consents, and proceeds with the patient assessment and drug regimen review – all at the same visit.  Key point:  the initial assessment and the comprehensive assessment are two separate requirements under the CoPs.

The waiver under the COVID-19 PHE applies only to the initial assessment – the initial assessment may be done remotely by phone or by reviewing the medical record but the SOC comprehensive assessment still requires an in-person visit to the patient.

Teresa Northcutt, BSN, RN, COS-C, HCS-D, HCS-H
Senior Associate Consultant, Selman-Holman, A Briggs Healthcare Company


  1. Hi. I have a questions regarding the SOC visit /Initial Assessment during Covid. I didn’t see any statement from the CMS that SOC assessment should be in-person. The way i understood it is that during SOC assessment is when you determine patient’s homebound status. If the waiver states that during Initial assessment, homebound status can be determine thru phone interview or record review. It didn’t really qualify if SOC falls under the “initial assessment”. But we all know that SOC is always considered the initial assessment in a home health setting whenever we admit a patient. During this pandemic, home health agencies have the responsibility to keep the patients at home, safe and healthy. When an MD ordered for home health but the patient refused a visit, there is a reason why the doctor ordered it and we also have to respect the patient’s decision to not have an outside person in their home despite explanation. And this is where the ability of home health to do initial assessment comes in without having the need to be in the home. I could be wrong, but this is how i understood the statement by CMS especially there is nothing on the memo that states “SOC”. Your explanation or any article from CMS about SOC during this crisis will be appreciated.

    1. The SOC comprehensive assessment and the initial assessment are two separate requirements in the CoPs. The initial assessment establishes eligibility (homebound) and is the one that can be done over the phone. The SOC comprehensive assessment requires an in-person assessment of the patient.

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