From everyone at Amity Healthcare Group, we would like to wish you happy holidays and thank you for your continued loyalty and faith in us.
It’s been wonderful working with you in 2023 and we hope we can continue working together in the forthcoming year. In the meantime, have a beautiful holiday season filled with love, warmth, happiness, and health!
AMITY’S NEWS
There are several questions that were brought up by our clients this week that we wanted to share with you. The responses to the questions are from the OASIS Q&A below.
We are heading to Orlando, Florida in January 2024 to participate in and present at ACHCU Academy annual educational event- Achieving Excellence– that will be held January 22-24, 2024.
Mark your calendars and save the dates for the following presentations by Irina Gorovaya, President of Amity Healthcare Group:
- January 22, 24-1:20 pm to 2:15 pm ET – Practical Guide to Home Health Competency Program
- January 22, 24-2:20 pm to 3:15 pm ET – The Critical Role of Medication Profile and Reconciliation Management in Home Health: A Guide to Effective Error Prevention
- January 23, 24- 10:00 am to10:55 am ET – Creating Patient Success with Individualized Home Health Plans of Care: Best Practices from Assessment to Execution
- January 23, 24- 1:20 pm to 1:15 pm ET – Specialized Care in Home Health: A Transformation in Patient Services
You can find out more about the event and register here: https://achcu.com/academy/
For a complete event agenda, please go HERE
Skilled Nursing Competency
We are almost at the end of the year. Do not forget to complete all of your annual home health requirements, including Annual Competencies for nurses.
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.
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.
OASIS -E Corner
I.) In this issue of our newsletter, we would like to bring your attention to the following question from the OASIS Quarterly Q&As 10/2023:
Question 4: We are seeking clarification for M1033 – Risk for Hospitalization; response 3 – Multiple hospitalizations (2 or more) in the past 6 months. In the Response Specific Instructions, it states “Multiple hospitalizations (Response 3) defines hospitalization as the patient being admitted for 24 hours or longer to an inpatient acute bed for reasons other than diagnostic testing.”
Does “inpatient acute bed” include inpatient facilities other than an acute care hospital? Specifically, would admission to any or all of the following facilities be considered an “inpatient acute bed” for M1033 response 3:
- Free-standing Inpatient Rehabilitation Hospital
- Inpatient Rehabilitation Unit within a hospital
- Inpatient Psychiatric Hospital
- Long-Term Care Hospital
Answer 4: M1033 – Risk for Hospitalization; response 3 – Multiple hospitalizations (2 or more) in the past 6 months includes only acute care hospitalizations.
Admissions to an inpatient rehabilitation hospital or unit (meaning a freestanding rehab hospital or a rehabilitation bed in a rehabilitation distinct unit of a general acute care hospital), an inpatient psychiatric hospital and long-term care hospitals (LTCHs) are excluded from this response option.
II.) Updated OASIS-E Manual
The Centers for Medicare & Medicaid Services (CMS) has released a revised Outcome and Assessment Information Set (OASIS)-E Manual with an associated Change Table.
Please note that there are no changes to the OASIS-E instrument. The changes incorporate guidance into the manual and Q&As from the CMS Quarterly Q&As dated July 2022 through October 2023.
Outcome and Assessment Information Set OASIS-E Manual (cms.gov)
Change Table Summarizing 2024 Update to the OASIS-E Guidance Manual (cms.gov)
NATIONAL NEWS
Additional Changes to Provider Enrollment
I.) Stay of Enrollment
CMS finalized a new enrollment status labeled a “stay of enrollment” at §424.541. The “stay of enrollment” is a preliminary, interim status to any subsequent deactivation or revocation that represents a “pause” in enrollment, during which the provider or supplier would still remain enrolled in Medicare.
There are two prerequisites for a “stay of enrollment” implementation:
- The provider or supplier must be non-compliant with at least one enrollment requirement in Title 42.
- The provider or supplier can remedy the non-compliance via the submission of, as applicable to the situation, a Form CMS-855 and Form CMS-588 change of information or revalidation application.
During the period of any “stay of enrollment,” the provider or supplier remains enrolled in Medicare, but claims submitted by the provider or supplier with dates of service within the stay period will be rejected rather than denied as was proposed. Claims submitted by the provider or supplier with dates of service within the “stay of enrollment” period are eligible for payment and may be resubmitted by the provider or supplier if they have come into compliance within the 60 day stay period.
The “stay of enrollment” will last no longer than 60 days.
II.) Reporting Changes in Practice Location.
- CMS finalized at §424.516(e)(2) to require practice location changes, additions, and deletions be reported within 30 days for all provider types.
- Also finalized that a change of practice location includes adding a new location or deleting an existing one.
Medicare Home Health Provider Compliance Tips
Please review the most recent Home Health provider compliance tips, including areas related to certification/re-certification of home health, medical necessity, and Face to Face HERE.
Home Health Prospective Payment System Grouper: January Update
Get the January 2024 release (v05.0.24) (ZIP). See Home Health Prospective Payment System Grouper Software for a summary of changes.
More Information:
- Section 80 Claims Processing Manual, Chapter 10 (PDF)
- Instruction to your Medicare Administrative Contractor (PDF)
Waived Tests
For home health agencies that perform waved tests under a CLIA Certificate of Waiver, please note that the list of waived tests has been recently updated and new tests were added (to review an updated list, please go to Tests Granted.
Waived Status Under CLIA table.
New OSHA Illness and Injury Log Requirements Begin January 1, 2024
Just a reminder that new OSHA illness and injury log requirements begin January 1, 2024.
Please remember that home health agencies are not on the list of industries/employers that are included in the OSHA form submission requirements for establishments with less than 250 employees.
However, all establishments with 250 or more employees (regardless of the industry) must electronically submit Form 300A, once a year. With that, large home health organizations will be required to comply with this requirement.
For more information, please go to: https://www.osha.gov/
COLORADO NEWS
Important Nursing License Compact Rule Changes
As you know, Colorado is a Nursing License Compact (NLC) member. As a result, it is important to remember that new NLC Rules will take effect on January 2, 2024, including the rule that requires nurses moving from one compact state to another compact state to apply for licensure in their new Primary State of Residence (PSOR) within 60 days.
To review a complete rule, please go HERE. For additional information (FAQs, recorded webinar, etc.), please visit https://www.nursecompact.com/
Pediatric Long-Term Home Health (PLTHH) Prior Authorization Request (PAR) Pause Extension
This means that PARs will not resume before Jan. 31, 2025, for all PLTHH services: nursing, CNA, PT, OT, and ST.
Home Health Agencies are reminded to continue providing and billing for only medically necessary and ordered services in accordance with state law. Failure to comply with medical necessity and benefit limitations in the regulations may result in compliance monitoring. This could include prospective and post-payment reviews of claims and recovery of any identified overpayment in accordance with state law.
The PAR pause only refers to pediatric authorizations. Adult Long-Term Home Health still requires prior authorization.
For a complete HCPF memo, please go HERE.
Amity’s newsletters will be archived on Amity’s Healthcare Group website at https://amityhealthcaregroup.
Please do not hesitate to reach out for any assistance or questions via email, phone, or 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
720-353-7249 (cell) 303-690-2749 (office) 720-398-6200 (fax)
www.amityhealthcaregroup.com
Amity Healthcare Group
Centennial, CO 80112