Amity Healthcare Group News
Skilled Nursing Competency
Are you looking for a solution for a comprehensive and robust nursing competency program?
The “virtual” Skilled Nursing Competency program offered by Amity Healthcare Group, LLC is designed to assist agencies in meeting initial 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.
ICD-10 Coding and Clinical Documentation Review
Did you know that Amity Healthcare Group provides ICD-10 coding and clinical documentation review for home health providers? If you are seeking to outsource your clinical documentation review and/or ICD-10 coding process on a long-term or temporary basis, please reach out to us for assistance. Our services include:
- 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
For more information, please visit us at https://amityhealthcaregroup.
With questions, please contact us at 303-690-2749 or email at ig@amityhealthcaregroup.com.
OASIS – E Corner
We wanted to highlight the following OASIS related question in this newsletter:
Question:- The Home Health Final Rule for Calendar Year 2024 finalized the removal of OASIS items M0110 – Episode Timing, M2200 – Therapy Need and the GG Discharge goals in 2025 but does not specify when exactly these items would be removed.
- Can CMS please provide the date for when these items will be removed from OASIS and if these changes, along with adding the new COVID item, will result in a new version of OASIS?
- Do providers still need to continue to complete these items until they are removed from the OASIS, or can a dash be used?
Answer:-
- CMS plans to remove M0110 – Episode Timing and M2200 – Therapy Need and the GG Discharge Goals from the OASIS instrument effective January 1, 2025. At this time, the new COVID item will be added.
- Data collection using the OASIS-E1 version of the instrument will begin with OASIS assessments with a M0090 date on or after January 1, 2025.
- Until these items are removed from OASIS, providers should continue to complete them following the item specific guidance found in the OASIS-E Guidance Manual – Updated January 1, 2024.
Please note that the Centers for Medicare & Medicaid Services (CMS) recently posted the draft of OASIS-E1 All Items instrument, scheduled for an effective date of January 1, 2025. The accompanying OASIS-E1 Manual will be released at a later date.
Beginning in 2025, home health agencies will need to collect OASIS data for all patients regardless of payor source. Existing exemptions will continue for those under the age of 18, receiving maternity services, or those receiving only personal care, housekeeping or chore services. It is anticipated that there will be a phase-in period from January 1, 2025 through June 30, 2025 during which failure to submit the data will not result in a penalty. Mandatory collection and reporting will begin with discharges on or after July 1, 2025.
NATIONAL NEWS
Independent Contractor Test Update
The Department of Labor’s updated Independent Contractor test was released on January 9, 2024 and published in the Federal Register on January 10, 2024.
This update is expected to significantly impact the way how companies can classify their workers. The revised Independent Contractor evaluation focuses on the “economic realities of the working relationship.” It seeks to distinguish whether a worker relies on the company for employment or operates as an independent business entity.
This assessment is based on six key factors:
- Potential for profit or loss based on managerial skill.
- Investments made by both the worker and the company.
- Duration and stability of the work relationship.
- Level of control exerted over the worker, including technological supervision and constraints on work hours.
- Importance of the work performed to the company’s operations.
- Skills and initiative demonstrated by the worker, including specialized skills and training dependence.
Home health/home care organizations that rely on 1099 workers will need to re-evaluate the manner they classify their workers in the light of the updated rule, especially given the nature of home health/home care operations, where workers often perform vital services within patient’s homes and organizations influence factors like the level of control exerted over workers and their specialized skills in caregiving.
The new rule is set to come into effect on March 11, 2024.
As the effective date approaches, please review FAQs issued by DOL for additional guidance.
HHCAHPS
If your home health agency is eligible for an exemption from participating in the HHCAHPS Survey for the CY 2025 APU (HHA served 59 or fewer survey eligible patients between April 1, 2022, and March 31, 2023), please remember to submit your Exemption Request Form for the CY 2025 APU by 11:59 PM Eastern Time March 31, 2024.
The form is available at https://homehealthcahps.org/.
For additional information, please also refer to the HHCAHPS Coordination Team Quarterly Review (CTQR) newsletter that contains:
- Guidance for HHAs on understanding their publicly reported HHCAHPS survey data, focusing on an explanation of why footnotes are assigned to some HHAs, along with tips for HHAs and survey vendors to try to avoid footnotes.
- The agenda and slides for the self-paced 2024 Introduction to the Home Health Care CAHPS (HHCAHPS) Survey training.
CHAP NEWS
CHAP has recently announced that compliance program standards will be incorporated into CHAP standards of excellence for home health, hospice, home infusion therapy, DMEPOS, pharmacy, and home care.
CHAP developed a new key performance area (KPA) named “Compliance Program” that will be embedded in all CHAP service line standards of excellence beginning in June 2024.
To preview the draft standards, please go HERE. Providers are encouraged to begin incorporating the compliance program standards into their operations prior to June 2024.
CHAP will be offering compliance program education and resources leading up to the implementation of the standards to help organizations ramp up their implementation.
Telehealth in Home Health
If your home health organization is utilizing telehealth, you may be able to help.
Researchers from Weill Cornell Medicine have contacted National Association for Home Care and Hospice (NAHC) regarding telehealth in home health care.
NAHC will be participating in an interview with the researchers soon. In preparation for the interview, NAHC needs to better understand how telehealth is currently used to care for home health patients. The following link is to a brief survey to better inform our discussion.
Survey link: https://www.surveymonkey.com/
CGS Educational Opportunities
Please note that CGS is partnering with Performant for three (3) live educational sessions that will help you to navigate the Recovery Audit Contractor (RAC) process.
The first session, Navigating the RAC Process-Medical Record Requests, Submission and Payment, is scheduled for February 29, 2024 at 1:00 pm -2:00 pm ET.
The webinar will provide an overview of the goals of the Recovery Audit Contractor program, including medical record requests, submission and payment, extension requests, and contact information.
To register for the event, please go HERE.
COLORADO NEWS
Provider Challenges: Loss of Eligibility and PAR Processing Times
The past several months have been quite trying for multiple home health/home care agencies providing long term support (LTSS) services (i.e., HCBS, IHSS, LTHH, etc.) for Health First Colorado members.
The challenges have been primarily related to loss of member eligibility and Case Management Agency (CMA) transition/PAR processing times and their impact on daily business operations.
We have reached out to the Colorado Department of Health Care Policy and Financing (HCPF) for recommendations on how providers may be able to address these challenges in a more efficient and productive manner.
Here is the response that we received from HCPF:
“We do recommend that you continue to submit eligibility escalation tickets for all denied claims that your agency has been experiencing. Our eligibility team continues to work closely with our county partners in escalating and resolving these cases. We are continuing to monitor the situation and provide assistance to our providers as much as possible during this critical time.
If you are experiencing any type of eligibility disruption that is significantly impacting business, please use this form for escalation purposes. This is irrespective of a case management and/or a county eligibility issue, technical issue, etc. Following any escalation, please submit the following information to Victoria Rogers, HCBS Residential Benefits Specialist, Office of Community Living (Victoria.Rodgers@state.co.us) via encrypted email.
- Member Name
- Member Medicaid ID
- Member County
- Member Case Management Agency
- Member Escalation Number (found via the escalation submission form)
Please keep in mind, this is primarily for providers that have members experiencing significant delays at the county level, relating to financial determination and processing (because of the PHE unwind). This process can also include CMA delays with PAR’s as well.”
Please note that if you have already submitted escalation request at the county level and/or at the CMA leadership level, as may be appropriate, please allow designated response time before submitting escalation request to HCPF. Please also use comments section in the HCPF escalation form to describe all previous steps/escalation attempts that were made with other authorities (i.e., county, CMAs, etc.).
HCPF Provider Updates
On January 5, 2024, HCPF issued an Operational Memo HCPF OM 24-001 for providers who require licensure and/or certification from CDPHE (please review the memo in its entirety for detailed information and step-by-step instructions).
According to the memo, providers enrolling in or adding one or more of the provider specialties (i.e., IHSS, Personal Care, etc.) must download their agency’s certifications from the CDPHE COHFI Provider Portal. Providers must attach their certification to provider applications, as necessary, in the HCPF Provider Web Portal.
Enrollment and maintenance applications submitted on and after the memo publication date (1/5/24) that do not have the required certifications attached, will be returned to providers or denied in the HCPF Provider Web Portal. Enrollment applications submitted prior to the publication date (1/5/2024) are not required to have a certification attached; HCPF will verify certification upon review.
Changes to the Code of Colorado Regulations (10 CCR 2505 – Volume 8)
On January 23, 2024, HCPF issued an Informational Memo HCPF IM 24-004 addressing upcoming regulatory changes that will effect providers in the light of the Case Management Redesign process.
Please review the memo and updated regulations found at CCR 2505-10 8.7400-7500 in their entirety for detailed information. As you are reviewing the updated rules and regulations, we encourage you to pay specific attention to the following sections:
- 8.7408 Policies and Procedures
- Section 7- Dispute Resolution
- 8.7410 Personnel
- Section C.1.- Medication Administration
- Section E.1.- Colorado Adult Protective Services (CAPS) and Criminal Background Checks
- 8.7412 Incident Reporting
- 8.7415 Medication Administration
Please note that the new regulations will go into effective on March 15, 2024. The changes will also impact surveying process completed by the Department of Public Health and Environment (CDPHE).
As provider agencies become familiar with the new regulations, agencies will have until September 30, 2024, to come into full compliance with the new regulations found at CCR 2505-10 8.7400-7500.
Please note that although provider agencies are not required to comply with the new regulations until September 30, 2024, Colorado Department of Health and Environment (CDPHE) will be conducting all initial and recertification surveys on these new regulations.
ARPA 7.02- Member Emergency Preparedness -Surviving in Place Emergency Go-Kits
With funding made available through the American Rescue Plan Act (ARPA) and in collaboration with The Center for Inclusive Design and Engineering (CIDE), HCPF will be distributing emergency go-kits to eligible Health First Colorado members.
An Emergency go kit is a collection of essential items specific to your needs that you can quickly grab and take with you in an emergency or evacuation.
It can contain all necessary supplies in one place for easy access in a hurry.
Go kits are customized based on any medications, assistive technology, or special needs that a member may have. Kits should be kept in a designated location, such as near the front door or in your car trunk, so it can be easily grabbed when needed.
If you are interested in getting a go kit, please complete the application. Once received, the application will be reviewed, information verified, and a determination made if the applicant qualifies. There is a limited supply and a final decision will be made on eligibility and the availability of kits. All questions should be directed to Julia Beems at 303-315-1284 or julia.beems@ucdenver.edu.
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.
If you wish to forward this email to your colleague or friend, please feel free to do so. If you received this message as a forward, we invite you to subscribe to our communications at https://amityhealthcaregroup.
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
