Amity Healthcare Group Weekly Newsletter Issue date: Jun 17th, 2022

Issue date: Jun 17th, 2022



Amity Healthcare Group is excited to announce its participation in Home Care Association of Florida 33rd Annual Home Care Conference – The Roaring Twenties that will be held in Orlando, Florida July 19-22, 2022.

Please join, Irina Gorovaya, Owner and President of Amity Healthcare Group, for a presentation – Telehealth in the “Rumble” Seat: New Norm, New Opportunity – on July 20, 2022, from 3:30 pm to 4:30 pm at Citron West room.

Irina will discuss current trends and potential opportunities for telehealth in home health and review existing regulations and legislature directing the use of telehealth in home health and hospice, as well as telehealth reimbursement. Irina will also discuss recommended American Telemedicine Association (ATA) standards for telehealth and provide guidance related to the successful deployment of a telehealth program in home health, including policies, documentation, staff education, and telehealth solutions.

Please also join, Lourdes Wiley, home health consultant and clinical educator, for a presentation – Compassion Fatigue & Burnout: New Perspectives for Health Care Providers, Teams, and Organizations – on July 22, 2022, from 10:35 am-11:55 am at Sunburst room.

Lourdes will discuss the effect of the burnout and compassion fatigue on the entire organization as well as the patients served. This presentation is intended to give clinicians and non-clinicians alike a new perspective on how to care for themselves, each other, and take ownership of creating a welcoming and healthier workplace for all. 

Skilled Nursing Competency Program

Amity Healthcare Group is offering a robust, live, instructor-led home health competency program for your skilled nursing personnel. The program includes:

  • Initial Onboarding Skilled Nursing Competency (2 hours)
  • Urinary Catheter and Ostomy Care Skilled Nursing Competency (1 hour)
  • Central Line/IV Skills Nursing Competency (1 hour)
  • Respiratory and Tracheostomy Care Skilled Nursing Competency (1 hour)
  • Wound Care Skilled Nursing Competency (1 hour)

These modules are available to home health providers nationwide.

For more information, questions or registration, please go to



Surveys for Compliance with COVID-19 Health Care Staff Vaccination Requirements

The Centers for Medicare & Medicaid Services (CMS) posted memo QSO-22-17-ALL containing new instructions for surveys for compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements.


As per previous guidance, federal, state and Accreditation Organization (AO) surveyors were to assess for compliance with the vaccination requirements at surveys for initial certification, standard recertification or reaccreditation, and complaint surveys.

Effective immediately, surveyors will continue to survey for compliance with the vaccination requirements during initial and recertification surveys but will now only survey for compliance in response to complaints alleging non-compliance with this requirement (not all complaint surveys).

This memo also instructs state survey agencies to reach out to their CMS Location if they are considering citing vaccine requirements at immediate jeopardy, Condition or actual harm levels. CMS is reviewing its previous interpretive guidance describing Immediate Jeopardy, Condition-level and actual harm determinations to ensure that deficiency citations recognize good faith efforts by providers/suppliers and to more fully evaluate harm or potential harm to patients/residents by considering trends in COVID-19 rates in the community.

CMS Revises Instructions for NPPs Ordering Home Health Services

You may remember that on April 27, 2022, CMS issued Medicare Benefit Policy Transmittal 11386 with revision to the guidance on non-physician practitioners (NPP) Home Health Certification. The revision included the following language from long standing regulations that define non-physician practitioners (NPPs):

“Physician assistant means an individual as defined at § 410.74(a) and (c). Clinical nurse specialist means an individual as defined at § 410.76(a) and (b), and who is working in collaboration with the physician as defined at § 410.76(c)(3). Nurse practitioner means an individual as defined at § 410.75(a) and (b), and who is working in collaboration with the physician as defined at § 410.75(c)(3)”

“In the absence of State law governing collaboration, collaboration is to be evidenced by NPs documenting their scope of practice in the medical record and indicating the relationships that they have with physicians to deal with issues outside their scope of practice.”

CMS has subsequently clarified that it interpreted states that allow full practice authority for nurse practitioners to be states that are absent state laws governing collaboration, and therefore, these practitioners would need to document in the medical record their scope of practice and the relationships that they have with physicians.

In response to this, NAHC and the American Association for Nurse Practitioners met with CMS to discuss their concerns with the interpretation of the regulation.

On June 9, 2022, NAHC informed the stakeholders that CMS has rescinded Transmittal 11386 that was issued April 27,2022 and replaced it with Transmittal 11447, dated, June 6, 2022. Transmittal 11447 removes Chapter 7, Section 30.2.1, titled Definition of an Allowed Practitioner that was part of the April 27, 2022, Transmittal.

According to NAHC, although CMS’ rescinding Transmittal 11386 pulls back that policy and places a hold on its enforcement, CMS is still deliberating their policy position on the requirement for NPPs to document their scope of practice and relationships with physicians.

NAHC will continue to advocate for reasonable policies for NPPs that order and certify home health services for Medicare beneficiaries.

Billing Update for Home Infusion Therapy (HIT) Providers

Billing Infusion Medications – WeInfuseIf you are a home health provider that is also enrolled as a Home Infusion Therapy (HIT) provider, please note the update to ‘J’ Drug Code List for Billing Home Infusion Therapy (HIT) Services.

The MLN matters publication (MLN Matters) addressed the following updates:

  • Updates due to Section 5012(d) of the 21st Century Cures Act detailing necessary changes to those systems and processes to include a newly assigned HCPCS drug code for payment beginning July 1, 2022.
  • Updates the list of home infusion drugs to add J1551 to payment category 2. The corresponding G-codes for category 2 drugs are G0069 or G0089

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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