Greetings !
This week we have the following sections covered under this newsletter.
Amity Healthcare Group team had an incredible experience at the ACHCU Achieving Excellence event in Dallas, March 3-5, 2025. It was a fantastic opportunity to learn, network with industry peers, and gain fresh inspiration. Amity’s Irina Gorovaya and Kelly Pineda took the stage to share their expertise, presenting multiple key topics that sparked insightful discussions.
The “virtual” Skilled Nursing Competency program offered by Amity Healthcare Group, LLC is designed to assist agencies in meeting initial onboarding and/or annual competency requirements for Registered Nurses (RNs) and Licensed Practical/ Vocational Nurses (LPN/LVNs) in the home health care setting. This comprehensive program serves as a robust introductory foundation to nurses new to the home health setting as well as an excellent “refresher” for experienced home health nursing staff.
Please note that our skilled nursing competency program is certified by Accreditation Commission for Health Care (ACHC) (learn more here).
For more information, questions, or registration for Amity’s home health skilled nursing competency program, please go to https://amityhealthcaregroup.
In this issue we would like to bring your attention to the following OASIS-related question:
Question: For the transition to all-payer, do we need to discharge and readmit non-Medicare/non-Medicaid patients who were on service in December 2024 and remained on service on or after January 1, 2025? Would this also apply to non-Medicare/ non-Medicaid patients who remain on services on or after July 1, 2025, when OASIS data collection is mandatory for all patients regardless of payer?
Answer: No, agencies do not need to discharge and complete a new SOC for non-Medicare/ non-Medicaid patients who are on service prior to 2025 and who remain on service on or after January 1, 2025. The same concept applies for patients who are on service during the voluntary phase and remain on service on or after July 1, 2025.
Just a reminder that it is a responsibility of qualifying Medicare-certified Home Health Agencies to participate every month in the Home Health CAHPS (HHCAHPS) Survey to obtain the full Annual Payment Update (APU) from the Centers for Medicare & Medicaid Services (CMS). The CY 2026 APU submission period is coming to a close on March 31, 2025, and the CY 2027 APU data collection period begins on April 1, 2025.
Agencies not participating in the HHCAHPS survey as required will receive a 2% APU penalty unless they meet one of the exemption requirements as mentioned below:
There are only two scenarios under which a Medicare-certified Home Health Agency can be exempt from participation in the HHCAHPS Survey:
- Being a newly certified Home Health Agency: if the Agency received Medicare certification from CMS after April 1, 2024, then the Agency is considered too new to participate in the CY 2026 APU. This is a one-time exemption only, and there is no application process for this exemption.
- Having serviced 59 or fewer survey eligible patients during the applicable year (period between April 1, 2023, and March 31, 2024): In this case, the Agency must complete a Participation Exemption Request form by March 31, 2025. Please remember that the exemption request must be completed annually, as long as the Agency continues to qualify for an appropriate exemption.
If your Agency does not qualify for an exemption, as noted above, but has not yet participated in HHCAHPS survey, you should make arrangements to do so to avoid a 2% penalty.
To get started with HHCAHPS, please follow the steps below:
- Contract with an approved HHCAHPS survey vendor to administer the HHCAHPS survey and submit HHCAHPS survey data to the HHCAHPS Data Center on the Agency’s behalf.
- Register for credentials to access the private links on https://homehealthcahps.org.
- Authorize an HHCAHPS survey vendor on https://homehealthcahps.org to collect and submit HHCAHPS survey data to the HHCAHPS Data Center. Additional instructions for authorizing a survey vendor are available here.
When it comes to maintaining compliance with provider enrollment, please remember the following:
- Change of Ownership (CHOW)
- Deactivation of Billing Privileges
Change of Ownership (CHOW):-
Providers and Suppliers (both parties) must report a change of ownership (CHOW) within 30 days of the change. For certified providers undergoing a CHOW, 42 CFR 424.550 states:
- Both the seller and the buyer must submit enrollment applications to report the CHOW.
- If the seller fails to submit an enrollment application to report CHOW, the seller may be sanctioned or penalized (even after the date of the ownership change).
- If the buyer fails to submit an enrollment application containing information about the buyer within 30 days of the CHOW, the provider’s billing privileges may be deactivated.
See Medicare Provider Enrollment for more information.
Deactivation of Billing Privileges: –
In the last month, we had several providers who received notification of deactivation of Medicare billing privileges.
Please remember that Medicare billing privileges may be deactivated in accordance with § 424.540 Deactivation of Medicare billing privileges for the following reasons:
Reasons for deactivation: CMS may deactivate the Medicare billing privileges of a provider or supplier for any of the following reasons:
- The provider or supplier does not submit any Medicare claims for 6 consecutive calendar months. The 6 month period will begin the 1st day of the 1st month without a claims submission through the last day of the 6th month without a submitted claim.
- The provider or supplier does not report a change to the information supplied on the enrollment application within the applicable time period required under this title.
- The provider or supplier does not furnish complete and accurate information and all supporting documentation within 90 calendar days of receipt of notification from CMS to submit an enrollment application and supporting documentation, or resubmit and certify to the accuracy of its enrollment information.
- The provider or supplier is not in compliance with all enrollment requirements in this title.
- The provider’s or supplier’s practice location is non-operational or otherwise invalid.
- The provider or supplier is deceased.
- The provider or supplier is voluntarily withdrawing from Medicare.
- The provider is the seller in an HHA change of ownership under § 424.550(b)(1).
Although the deactivation of Medicare billing privileges does not have any effect on a provider’s participation agreement/Medicare certification or any conditions of participation, it is important to take appropriate steps to reactivate the billing privileges.
- In order for a deactivated provider or supplier to reactivate its Medicare billing privileges, the provider or supplier must recertify that its enrollment information currently on file with Medicare is correct, furnish any missing information as appropriate, and be in compliance with all applicable enrollment requirements in this title.
- CMS may, for any reason, require a deactivated provider or supplier to, as a prerequisite for reactivating its billing privileges, submit a complete Form CMS-855 application.
- Reactivation of Medicare billing privileges does not require a new certification of the provider or supplier by the State survey agency or the establishment of a new provider agreement.
Please also note that the providers will have an opportunity to submit a rebuttal statement in response to the notice of deactivation, if the provider believes that the deactivation is incorrect.
As you know, effective February 3, 2025, HCPF started a soft launch period for the submission of Pediatric LTHH therapy PARs for Physical Therapy (PT), Occupational Therapy (OT), and Speech Therapy (ST). The soft launch is a voluntary period for providers to submit PARs for medical necessity review by Acentra Health, the current Colorado UM vendor. A PAR will be approved for up to one year. A determination that would typically result in a denial or reduction in hours will not trigger a formal denial but rather allow the member’s services to continue uninterrupted while allowing the home health agency (HHA) to gain valuable feedback and education regarding the PAR process.
The soft launch will remain available for therapy PARs only until the Maintenance of Effort (MOE) requirement for Colorado is lifted by the Centers for Medicare and Medicaid Services (CMS), but not before May 1, 2025.
It is still anticipated that July 1, 2025 will be a go-live date for Pediatric Long Term Home Health Nursing and CNA PARs.
By now, all of you have probably heard of upcoming changes related to the implementation of a Nurse Assessor program by the Colorado Department of Health care Policy and Financing that is anticipated to go live on Jully 1, 2025. The Nurse Assessor Program will impact long term home health, PDN, and IHSS HMA services. The Nurse Assessor implementation continues to be a fluid matter, and we are still awaiting for specific rules and instructions related to the process.
At this time, we know that Telligen has been selected as a vendor for the Nurse Assessor Program. It is anticipated that the contract will be completed in April of 2025.
Meanwhile, as we are learning more and more about the Nurse Assessor Program, we would like to encourage you to stay involved in all stakeholder participation opportunities as related to Nurse Assessor Program and, if you have not attended Nurse Assessor meetings held by HCPF in February and March, please listen to the meeting recordings. The recordings, as well as other updates, may be located at https://hcpf.colorado.gov/
During March 18, 2025, Long Term Home Health Office Hours meeting with HCPF, the providers were reminded of the following requirements as related to the provision of care by CNAs:
- CNA visits provided in a shift (visits lasting more than 4.5 consecutive hours) are not a covered home health benefit. If a patient requires extended CNA care, as based on medical necessity, the Agency should ensure that there is at least 30 minutes to 1 hour break between consecutive CNA visits.
- Extended CNA visits should not be utilized in place of PDN services. CNA visits, or requests for extended visits, for the sole purpose of Protective Oversight are not reimbursable by Medicaid.
- The basic unit of reimbursement for CNA services is up to one hour. A unit of time that is less than fifteen minutes cannot be reimbursed as a basic unit.
- For CNA visits that last longer than one hour, extended units may be billed in addition to the basic unit. Extended units shall be increments of fifteen minutes up to one-half hour. Any unit of time that is less than fifteen minutes cannot be reimbursed as an extended unit.
Providers were encouraged to review their corresponding processes and engage in self-auditing to prevent any non-compliance – “the Colorado Department of Health Care Policy & Financing (HCPF) encourages providers to be active participants in ensuring the financial integrity of our healthcare programs. HCPF strongly encourages all providers to routinely conduct internal self-audits and to disclose any overpayments of funds.”
HHSC – April 17 HCSSA Provider Webinar
HHSC Long-Term Care Regulation (LTCR) will host a webinar for Home and Community Support Services Agencies (HCSSA) on April 17 from 11 a.m. to noon.
LTCR will provide the latest updates and take live questions from participants.
Amity’s newsletters will be archived on Amity’s Healthcare Group website at https://amityhealthcaregroup.
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Thank you,
Irina Gorovaya, RN BSN, MBA
Amity Healthcare Group, LLC
Home Health Consulting, Education and Outsourcing Services
713-564-5011 (Houston Office), 303-690-2749 (Denver Office), 720-398-6200 (fax)
https://amityhealthcaregroup.
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Amity Healthcare Group
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