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Home care can be tricky and you simply can't afford to make mistakes. Through our auditing services, we will provide you with a snapshot of how your agency adds up in each of our specialized auditing areas. Our audit services include a private coaching session with one of our experts explaining the findings. Let MAC Legacy help you find areas for improvement and opportunity.

Our Auditing Services Include:

  • Chart Audit and Review
  • OASIS Audit and Review
  • Therapy Audit and Review
  • ICD-10 Start of Care Coding Audit
  • Patient-Driven Groupings Model (PDGM)
  • Review Choice Demonstration
  • Emergency Preparedness Plan Audit and Review

Mock Audit and Consulting Services
Today's demands on home health/hospice administrators are greater than ever with Medicare cuts and new protocols. With a comprehensive on-site evaluation of your agency, MAC Legacy can assist in building on your staff's strengths and recognizing your weaknesses through customized training and consulting. Our experienced staff will offer solutions and recommendations that will result in improved quality of care, cost-effective strategies and increased efficiencies.


  • Annual Evaluation
  • Billing/Reimbursement
  • Chart Audits
  • Coding Evaluation & Training
  • Financial Management Analysis
  • OASIS Evaluation & Training
  • Outcomes Based Quality Improvement
  • Performance Improvement Initiatives
  • Productivity Levels
  • Risk Management & Referral Database
  • HIPAA Compliance & Gap Analysis


  • Compliance Plans
  • Executive Placement
  • Personnel Management
  • Policy Implementation
  • Regulatory Training
  • Internal Analysis
  • Productivity Levels
  • Strategic Initiatives

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Under the current reimbursement system, there are no margins for error. MAC Legacy the solution for accurate home care and hospice coding, sequencing, and optimal reimbursement. By partnering with an industry-leading service, your field staff and case managers will have more time to focus on quality patient care and proper documentation. Coding-To-Go gives your agency access to Certified Home Care & Hospice Coding Specialists (HCS-D & HCS-H), who are audited for accuracy.

Benefits of Coding-To-Go:

  • 24 hour turnaround
  • Guaranteed accuracy
  • Optimized reimbursement
  • Reduced stress
  • More time for clinicians
  • No long-term commitment

How to get started:

  • Contact your MAC Legacy: or 800.213.4732
  • Receive and complete your start-up packet
  • Meet our team
  • Submit your claims!

Additional Service:

  • OASIS Review
  • Star Review

Have a dedicated coding staff? We've got your covered on sick days, vacation days, and influx of high volume. Let MAC Legacy help you with all your outsource coding needs!

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Welcome to the FMS Online University!

FMS Online University gives you the opportunity to choose from our ever-expanding online library. Our online education offers flexibility for your field clinicians to have access to education on demand.

FMS online training offers a comprehensive library providing training and education to most disciplines. You can choose online training to review a topic, to investigate a new specialty, or to gain in-depth knowledge. Training is rated by degree of difficulty and some are offered in a series.

Link to FMS University here!

Does the majority of your staff need training? Let FMS come to you. Drawing from decades of experience, our team of experts provide onsite training in a wide variety of subject areas. This customizable education option is as cost-efficient as it is convenient.

FMS offers:

  • Current, cutting-edge training for all your clinical and non-clinical staff
  • Continuing education hours for administrators, nurses, therapists, and social workers
  • Nationally recognized expert instructors who make learning fun
  • Instruction that simplifies complicated and constantly changing industry regulations

Sample topics include:

  • Coding
  • Documentation
  • Home Health Survey Protocols
  • Therapy

Interested in having FMS teach at your site? Ask us how.

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Expert Feedback

Your question is important to us.  Our goal is to find or create a solution for you as quickly as possible.  Below, our experts have addressed some of the most common questions.  If you don’t see your inquiry below, please contact us at any time.


Can a Coder Assume a Relationship between Hypertension and Heart and/or Kidney Involvement?

The assumptions with Hypertension have been more difficult to embrace. For some time coders have accepted the assumption of a cause and effect relationship between hypertension and chronic kidney disease. But now the guidelines specifically address the relationship between hypertension and heart involvement, as well as kidney involvement. Coding Guidelines states: “These conditions should be coded as related even in the absence of provider documentation explicitly linking them, unless the documentation clearly states the conditions are unrelated.”

The assumption is made by the classification between HTN and Heart Disease (I11.- and I13.- codes). When heart disease is present with HTN, such as CHF and HTN, code it using a code from category I11 followed by an additional code for the type of heart failure.

What if the patient has HTN, CKD, and heart failure? As long as there is not other documentation indicating another cause for the heart failure or kidney disease use a code from category I13 followed by a code indicating the stage of CKD and a code for the type of heart failure.


I am confused about a patient having hypertension and chronic diastolic CHF and linking those conditions without the physician documenting a causal relationship. I understand the causal relationship between diabetes and what conditions appear under the word “with” but the hypertension is not as clear.

Coding Clinic in May 2016 advised home health coders that the word “with” in ICD-10 coding manuals should be interpreted to establish a cause-and-effect relationship between a diagnosis and the subterm condition linked to it.

Heart failure can occur independent of other conditions, although it is most often associated with another diagnosis. Many of these are presumed causal relationships linked by the terms “with,” “in” or “due to” in the alphabetical index or tabular list. The most common is hypertension.

 This link is presumed under the following conditions:
1.       The patient has both the diagnosis and the subterm condition confirmed by the physician, and
2.       There is no other cause provided for the subterm condition.
Specific documentation from the physician linking the diagnosis and the subterm condition is not required if these two requirements are met. With the patient you described it would be coded as:
I11.0, Hypertensive heart disease with heart failure
I50.32, Chronic diastolic (congestive) heart failure

It’s confusing that Medicare uses the term “episode” in more than one way – for the payment episode and for the outcome episode. Why did they do that?

You are correct!  It is confusing. For Medicare payers, the first 60-day certification period or “payment episode” begins with SOC and ends on day 60, subsequent recertification periods are also 60 days long (for example, day 61 through day 120).  On January 1, 2020, PDGM introduced two 30-day payment periods within the 60-day episode. However, one Plan of Care continues to cover the 60-day episode.

For home health quality measures based on OASIS data (process measures & outcome measures), the “care episode” aka “quality episode” begins with every SOC or ROC and ends with every Transfer or Discharge.  It is possible for a quality episode to be less than 60 days (for example, beginning with SOC and ending with a Transfer on day 34) or much more than 60 days (for example, beginning with a ROC and ending with a Discharge 90 days later).


My patient has a history of heart failure that has caused her to be hospitalized three times last year. In the past 6 months, she has been stable with no medication changes and no active symptoms. I would like to keep her on Observation and Assessment (O&A) because I know there is a likelihood that she will go back into heart failure. Is this okay with Medicare?

No. The Medicare Benefit Policy Manual, Section, states that O & A is reasonable for three weeks. It may be reasonable for longer time periods if there is documentation of unstable condition. Some examples of this would be unstable labs, vital signs, weight changes, edema, or medication changes. The regulation goes on to say that a longstanding pattern of patient’s condition or no attempt to change treatment makes O & A unnecessary.


May a dentist refer and sign orders for a patient to receive home health care under the Medicare benefit?

No. According to Condition of Participation §484.18: Acceptance of Patients, Plan of Care, and Medical Supervision, care follows a written plan of care established and periodically reviewed by a doctor of medicine, osteopathy, or podiatric medicine.


How many hours of education per year is a home care aide required to complete?

The Federal Conditions of Participation, §484.36(b)(2), requires documentation of 12 hours of in-service training per year for home care aides. The training must be more than basic skills and must be supervised by an RN.


We recently received a referral from a hospital on a patient that was being discharged home. The discharge planner requested for us to admit the patient at the hospital so that hospice would pay for the ambulance ride home. Would we be responsible for that ambulance transportation?

In this situation, you would not be responsible for the cost of ambulance transport.  Hospice is responsible for transportation needs that are related to the hospice diagnosis and occur after the election date.  However, CMS does not consider it the hospice’s responsibility to pay for ambulance transports which occur on the effective date of the hospice election, but prior to the initial assessment and prior to the plan of care’s development.  The regulations also state that the initial assessment must be conducted in the location where hospice services will be provided, and the plan of care is developed from that initial assessment and from the comprehensive assessment.


What must be included in “acceptable” Face-to-Face (F2F) encounter documentation for a home health patient?

In order for the home health agency to consider it complete, F2F supporting documentation within the certifying physician’s medical record must contain: (1) Information that justifies the referral for Medicare HH services – the patient is homebound and in need of skilled services; and (2) the actual clinical note for the F2F encounter that occurred within the required timeframe, was related to the primary reason for home care, and was performed by an allowed provider type. In addition to obtaining the actual visit note, the home health agency may supply to the certifying physician information from the comprehensive assessment that supports the patient’s homebound status and need for skilled care. This HHA-generated information must be signed by the certifying physician. It is the home health agency’s responsibility to ensure the certification (including documentation of F2F) is complete prior to billing the final claim. [For specific CMS guidance on certification and F2F, refer to the Medicare Benefit Policy Manual, chapter 7, section 30.5 – Physician Certification and Recertification of Patient Eligibility for Medicare Home Health Services.]


Why does our CASPER report have a different percentage for Acute Care Hospitalization (ACH) than we see on Home Health Compare and in our Quality of Patient Care Star Rating preview reports?

One reason for differences when comparing an outcome measure percentage on your CASPER report and that same measure on HHC is due to differences in the risk-adjustment methodologies (for example, an agency’s percentage for “Improvement in Ambulation” might be 72% on CASPER and 76% on HHC because of risk-adjustment).


Yesterday I was preparing to lock up the office at the end of the day and found copied time sheets in the garbage with patient’s names. A cleaning crew empties all our garbage cans into a nearby dumpster twice weekly. Does this violate our patient’s privacy?

Definitely. When any document with Personal Health Information is no longer needed, it should be disposed in a secured document disposal container or shredded immediately.


What is Medicare?

Medicare is a health insurance program for:

  • People age 65 or older,
  • People under age 65 with certain disabilities, and
  • People of all ages with End-Stage Renal Disease (permanent kidney failure requiring dialysis or a kidney transplant).

Part A Hospital Insurance – Most people don’t pay a premium for Part A because they or a spouse already paid for it through their payroll taxes while working. Medicare Part A (Hospital Insurance) helps cover inpatient care in hospitals, including critical access hospitals, and skilled nursing facilities (not custodial or long-term care). It also helps cover hospice care and some home health care. Beneficiaries must meet certain conditions to get these benefits.

Part B Medical Insurance – Most people pay a monthly premium for Part B. Medicare Part B (Medical Insurance) helps cover doctors’ services and outpatient care. It also covers some other medical services that Part A doesn’t cover, such as some of the services of physical and occupational therapists, and some home health care. Part B helps pay for these covered services and supplies when they are medically necessary.


Occupational Therapy can conduct the comprehensive assessments subsequent to the start of care?

The Conditions of Participation are silent on who does perform comprehensive assessments after the start of care. OASIS Guidance Manual: Any discipline qualified to perform assessments-RN, PT, SLP, OT-may subsequent assessments.


I am an RN and I am responsible for looking at the content of therapy notes. What do I need to focus on in my record review?

Therapy evaluations should contain objective measurements for range of motion, strength, balance, as well as assistance needed to complete ADL and IADL tasks. Therapy goals should be measureable and have a functional component, i.e.: Pt. will ambulate from bedroom to kitchen using walker independently to retrieve morning medication safely. Therapy notes should clearly tell a story of what took place during the treatment–patient’s status prior to the treatment, any skill done during the treatment and how the patient responded to the treatment. The discharge summary should contain the goals set and if they were met, and if they were not met, the reason why.


How often does the PT have to see a patient that is being seen by a PTA?

This will depend on the state practice act, as states rules on supervision vary from state to state. Medicare requires the qualifying therapist, in this case the PT, perform a functional re-assessment of the patient at least every 30 days. This requirement is outside of the PTA’s scope of practice; therefore, the PT must perform this visit.


We have a home health agency in Texas. Are we required to post the Rights of the Elderly in the agency’s office?

Yes. Per Section 102.004 of the Texas Human Resources Code, an individual, corporation, association, partnership, or other private or public entity providing convalescent and nursing home services, home health services, or alternate care services must display the Texas Rights of the Elderly Poster in a conspicuous location for residents and employees to view.


I am a volunteer for a hospice agency in south Texas. Recently, the administrator informed me that the agency was required to perform an annual criminal background check. I only go to patients homes once or twice per month. Is this background check really necessary?

An agency must conduct a criminal history check authorized by, and in compliance with, Texas Health and Safety Code (THSC), Chapter 250 (relating to Nurse Aide Registry and Criminal History Checks of Employees and Applicants for Employment in Certain Facilities Serving the Elderly or Persons with Disabilities) for an unlicensed applicant for employment and an unlicensed employee. The agency must not employ an unlicensed applicant whose criminal history check includes a conviction listed in THSC §250.006 that bars employment or a conviction the agency has determined is a contraindication to employment. The criminal history check must be performed at least every 12 months for unlicensed employees who have face-to-face encounters with an agency’s patients. The provisions in this subsection apply to an unlicensed volunteer if the person’s duties would or do include face-to-face contact with a client.


I’m in Texas and last week, one of my patients said she thinks the home health aide may have stolen some money from her purse. When I told the patient that I would report this to my supervisor, she begged me not to tell and said “just forget it”. Am I obligated to report this?

Yes, you must report this. The Texas Administrative Code, Rule §4.554 outlines the regulation regarding abuse, neglect, and exploitation (ANE) of a client by an employee of the agency. It states that if an agency has cause to believe that a client served by the agency has been abused, neglected, or exploited by an agency employee, the agency must report information immediately. Texas regulations require that your agency has a policy on ANE and enforces it.


Can you share some helpful websites with me?