Amity Healthcare Group Weekly Newsletter Issue date: August 12th, 2022

Issue date: August 12th, 2022

Hello, Everyone!


Did you know that…

Amity Healthcare Group provides ICD-10 coding and documentation review as follows:

  • ICD – 10 Coding
  • OASIS Review + ICD – 10 coding
  • OASIS Review + POC (Plan of Care) Review
  • OASIS Review + ICD – 10 Coding + POC (Plan of Care) Review
  • Episodic documentation review
  • Quality Trends Analysis and QAPI Development

Take advantage of the optimal reimbursement with the precise ICD-10 coding, accurate documentation, and improved quality scores.

For more information or a free trial, please contact us at 303-690-2749 or email at


Preserving Access to Home Health Act- Legislation to Stop Home Health Rate Cuts

As we discussed in our last newsletter, it was estimated that 44 percent of all home health agencies would operate at a financial loss in 2023 if the 7.69 percent rate cut takes effect, triggering not only a loss of revenue, but most importantly, a loss of care access for the millions of people relying on home health services.

Fortunately, with the tremendous efforts  from NAHC and Representative Terri Sewell (D-AL) and Vern Buchanan (R-FL)  and Senators Debbie Stabenow and Susan Collins, legislation (Preserving Access to Home Health Act,) has been introduced in the House of Representatives to prevent cuts to the Medicare Home Health payment rate as proposed by the Centers for Medicare and Medicaid Services (CMS) in their Calendar Year 2023 rulemaking.

“This legislation should secure continued access to care,” added Dombi. “It will also provide an extended opportunity for CMS to rethink its approach to the budget neutrality adjustment. We firmly believe that CMS has much better options to consider that do not devastate the care that millions depend on.  Our great thanks for out to Representatives Sewell and Buchanan.”

The legislation would prevent the proposed cut from taking effect and will maintain the current payment rate while allowing for annual market basket inflation updates, until 2026. As the result, this would extend stability for providers and Advocacy & Policy – National Association for Home Care & Hospicepatients.

In addition to the legislation, NAHC has also launched a major grassroots effort to get the entire home health community involved in preserving a continued access to care for the millions of Americans dependent on home health services and as well as a general well-being and state of the home health industry.


For additional perspective on the introduced legislation, please review the following article: ‘We’re in the Fight’: The Preserving Access to Home Health Act Is Introduced in the Senate HERE.

Bill to Extend PHE Telehealth Flexibilities Advances in Congress

Another 90-day extension/renewal of Public Health Emergency (PHE) declaration that went into effect on July 15, 2022 will allow health care providers and state health departments to  have continued access to flexibilities  and waivers from the Centers for Medicare and Medicaid Services (CMS) for certain requirements under Section 1135 of the Social Security Act.

President of the National Association for Home Care & Hospice, William A. Dombi, responded to the PHE extension as follows:

“This is very welcome news,” said Dombi. “We hope that CMS and the Congress can reach conclusion on which waivers should be made permanent over the coming months. We have learned a lot about valuable policy reforms during the pandemic, including telehealth and avoidable administrative burdens.”

One of the examples of how the pandemic-related flexibilities could possibly transition into a permanent practice/rule is the legislation to extend telehealth waivers until the end of 2024. The legislation passed by the U.S. House of Representatives on July 26, 2022, when the House Rules Committee moved the Advancing Telehealth Beyond COVID-19 Act forward in an almost unanimous vote.

In summary, H.R.4040 bill modifies the extension of certain Medicare telehealth flexibilities after the end of the COVID-19 public health emergency and allows those certain flexibilities continue to apply until December 31, 2024, if the emergency period ends before that date. The bill allows:

  • beneficiaries to continue to receive telehealth services at any site, regardless of type or location (e.g., the beneficiary’s home).
  • occupational therapists, physical therapists, speech-language pathologists, and audiologists to continue to furnish telehealth services.
  • federally qualified health centers and rural health clinics to continue to serve as the distant site (i.e., the location of the health care practitioner).
  • evaluation and management and behavioral health services to continue to be provided via audio-only technology; and
  • hospice physicians and nurse practitioners to continue to complete certain requirements relating to patient recertifications via telehealth.

“The bill gives Congress, Medicare, and stakeholders time to produce a permanent policy with any necessary program integrity measures and benefit qualifications on a complex set of issues,” said NAHC President William A. Dombi. “For home health and hospice, it preserves, at least temporarily, the very valuable option of telehealth visits to meet the face-to-face encounter requirements under the respective benefits.”

This bill opens the doors for an additional discussion and consideration related to the opportunity for providers to be paid for the telehealth services and brings the industry one step closer to permanently expanding telehealth services.

CMS Issues NOA System Corrections

The Centers for Medicare & Medicaid Services (CMS) has release Change Request (CR) 12790 with the purpose to modify original Medicare systems to ensure prior periods are updated correctly when a Notice of Admission is canceled. It also ensures medical review information is not removed when claims are subsequently adjusted due to period sequence edits.

According to the CR 12790, when an NOA is submitted indicating the beneficiary transferred from another home health agency (HHA) and the NOA “from” date falls within the HH period of care of the previous HHA, the “end” date of the previous period is truncated to allow the transfer. If a transfer NOA is submitted in error and subsequently canceled, the TOB 032D will remove the transfer HHA’s admission period but will not restore the original calculated 30-day End date on the period of the previous HHA. This requires the previous HHA to cancel and resubmit their NOA before any of their claims can be processed. This is an avoidable administrative burden on that HHA.

Also, Medicare Administrative Contractors (MACs) have reported an issue with claims which have been medically reviewed and are later identified for adjustment due to an incorrect period sequence. In processing the adjustment, Medicare systems changes the User Action Code from the code applied by the medical review to “Z.” This erase additional medical review coding on the claim.

If the provider is still on review, this will trigger an unnecessary additional record request to the provider. If the provider is no longer being reviewed, the claim continues processing without the medical review coding, which impacts medical review reporting.

Please note that the updates are effective for claims processed on or after January 1, 2023.

CMS Releases Quarterly OASIS FAQs

The Centers for Medicare and Medicaid Services (CMS) has released the July, 2022 Quarterly Outcome and Assessment Information Set (OASIS) (please view HERE).

Please note that this FAQ release clarifies questions on items that are included in the OASIS-E.  CMS also noted that at times it provides new or refined instruction in the FAQs document that supersedes previously published guidance. In such cases, CMS recommends using the most recent guidance.

Navigating HHVBP Performance Feedback Reports

On August 25th from 2:00 pm ET – 3:00 pm ET, the Home Health Value-Based Purchasing (HHVBP) Technical Assistance (TA) Team will present Navigating Performance Feedback Reports: Interim Performance Report (IPR) and Annual Performance Report (APR).

Understanding the content of each report is essential to an HHA accurately and efficiently monitoring data to interpret their total performance score and potential payment adjustments and inform quality assurance and performance improvement (QAPI) initiatives. During this event, the TA Team will introduce the two (2) types of expanded HHVBP Model performance feedback reports: Interim Performance Reports (IPRs) and Annual Performance Reports (APRs). 

Content will include a review of the purpose, availability, timing, and location of the reports, followed by a walkthrough of each report type and the content on each tab in the reports. The event will also include a segment showing how data populates from one table to another.

You can register for the webinar at:

If you are not able to attend the event at its scheduled time, an audio recording, slides, and the transcript will be available on the Expanded HHVBP Model webpage shortly after the live event.

Please remember that your sample Interim Performance Report (IPR) and Annual Performance Report (APR) reports should be available in iQIES. As you are you are visiting your iQIES portal, please do not forget to check your Agency’s Preview Reports and Star Rating Preview Reports for the October 2022 Refresh.


Please note that for this refresh, Home Health (HH) Outcome and Assessment Information Set (OASIS) will be based on the standard number of quarters. Due to the COVID-19 reporting exceptions, the claims-based measures have been calculated excluding Q1 and Q2 2020 data from measure calculations. The HH QRP claims-based quality measures will not be refreshed for the October 2022 public reporting refresh. The HH QRP claims-based measures will next be refreshed for the October 2023 public reporting refresh of Care Compare and the Provider Data Catalog. 


Covid-Related Public Health Emergency Leave is Still in Effect

Just a reminder for all Colorado employers that regardless of size or industry, you are still required to provide “accrued” paid sick leave and public health emergency (PHE) leave to your employees under the Colorado Healthy Families and Workplaces Act (HFWA).

Colorado’s 80-hour COVID-related PHE leave continues as long as a COVID-related emergency remains “declared by a federal, state, or local public health agency” (C.R.S. § 8-13.3-402(9)), and both federal and state COVID-19 emergencies remain in effect. The right to HFWA COVID-related leave continues “until four weeks after” all applicable public health emergencies end or are suspended. As of publication, the earliest the PHE leave will end is November 10, 2022.

For more information on paid sick leave, please see the Division of Labor Standards and Statistics’ HFWA webpage.

Rocky Mountain Human Services- Reverse Provider Town Hall

The first RMHS Reverse Provider Town Hall meeting is happening on August 30, 2022, at 10 a.m. What is a Reverse Provider Town Hall you may ask? This is a virtual provider fair where our case managers can learn about the services you provide. RMHS  will be inviting case managers and recording the event so that case managers can hear from you.

Please plan on spending five minutes telling RMHS about your agencies, programs, resources, and, of course, openings. You can sign up by using this link.

If you are not able to attend the event but want to send information about your agency, please send to

RMHS is also asking you to email at if you have openings or staff available to serve people who are looking for providers. In the email please share:

  • Name:
  • Organization:
  • Current service availability:
  • Dates you have availability:
  • Neighborhoods in the Denver metro area you can serve:
  • Who to contact:

In addition, RMHS would like to hear from you. Please use the link (Survey) to take a quick satisfaction questionnaire to help RMHS continue to improve services

Amity’s newsletters will be archived on Amity’s Healthcare Group website at  under  Resources/ Our Newsletter section.

Please do not hesitate to reach out for any assistance or questions via email, phone, or website at

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Thank you,
Irina Gorovaya, RN BSN, MBA
Amity Healthcare Group, LLC
Home Health Consulting, Education, and Outsourcing Services
720-353-7249 (cell) 303-690-2749 (office) 720-398-6200 (fax)


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