Amity Healthcare Group Weekly Newsletter Issue date: March 29th 2023

Issue date: March 29th 2023

Amity’s News!

Attention Colorado HCBS Providers and Direct Care Workers!

Amity Healthcare Group is excited to announce that starting April 1, 2023, we will be offering free specialized dementia training courses for Colorado HCBS providers/direct care workers.

Providers will be able to select from the following courses:

  • The Alzheimer’s and Dementia Caregiving at Home (available on Mondays and Wednesdays)
  • Creating Safe Home Environment for People Living with Dementia and Alzheimer’s Disease (available on Fridays)

To register for your free course, please go HERE

ACHC Product Certification- Emergency Preparedness Plan

We are also excited to announce that Amity Healthcare Group received additional ACHC product certification for Emergency Preparedness Plan for home health and home care providers.

We now offer the following ACHC certified products for home health and home care agencies:
* Home Health and Home Care admission packet
* Home Health and Home Care QAPI program
* Home Health and Home Care Emergency Preparedness Plan
* Home Health Skilled Nursing Competency Program

For more information about our CHAP and ACHC certified products, please call 303-690-2749 or email
Please also visit our website at

OASIS -E Corner

What is considered a surgical wound for OASIS purposes?

M1340 Does this patient have a Surgical Wound?

  • Ostomies
    • A bowel ostomy is excluded as a surgical wound unless a “take down” procedure of a previous bowel ostomy is performed and the take down produces a surgical wound.
    • All other ostomies are excluded from consideration under this item and should not be counted as surgical wounds.
  • PICC line is NOT a surgical wound when it is peripherally inserted.
  • Examples of wounds to be reported as surgical wounds for M1340:
    • Orthopedic pin sites,
    • Central line sites (centrally inserted venous catheters)
    • Wounds with drains
    • Medi-port sites and other implanted infusion devices (whether accessed or not and as long as the device remains in place)
      • Medication pumps
      • Catheters for peritoneal dialysis
    • Venous access devices
    • AV fistulas (as long as it is present in patient’s body)
  • Debridement is NOT considered a surgical wound.
  • Abscess that is incised and drained is NOT a surgical wound (simple I&D)

Handy cheat sheet for M1340


CMS Clarifies Telehealth Reporting on Home Health Claims

The National Association for Home Care & Hospice (NAHC) has received clarification from the Centers for Medicare & Medicaid Services (CMS) regarding a several issues concerning submitting claims with the new G-codes for telehealth encounters.

CMS has indicated that they do not want home health agencies (HHAs) to submit a claim if the only services provided were via telecommunications technology.

This position is in line with CMS’ policy that HHAs are not to submit claims for payment periods without billable visits.  While CMS recognizes that some data may be lost, they balanced that against the disruption and costs of changing a longstanding process. CMS will reconsider its position in the future after some experience with the data.

Additionally, CMS issued Change Request (CR) 12805 that updates the Medicare Claims Processing Manual and provides instructions to the Medicare Administrative Contractors (MACs) on reporting the new G codes for telehealth services on home health claims. In that CR under Business Requirement 12805.4 CMS states:

The contractor shall return to the provider claims containing HCPCS codes G0320, G0321 and G0322 if there is not another line item on the claim with the same revenue code and a G HCPCS code other than G0320, G0321 and G0322. Example: A claim with a line reporting revenue code 0551 and G0320 must also have a revenue code 055x line containing HCPCS G0299, G0300, G0162, G0493, G0494, G0495, or G0496.

The instructions required the MACs to include an edit that returned a claim to the provider if there was  a G-code for a telehealth service without an onsite visit for that same discipline reported on the claim. NAHC requested clarification from CMS for this edit since there is nothing in CMS’ policy or regulation that requires such claims reporting.

CMS reconsidered the edit and determined it was incorrect. The MACs have turned-off the edit.  In the February 9, 2023, Medicare Learning Network Connects© newsletter, CMS noted the error and instructed providers to resubmit any impacted claims.

CMS will issue a CR in October that will permanently remove the edit from Medicare systems and  revise the manual to be clearer that claims with no billable visits are not to be submitted (including claims with only telehealth services).

Important Home Health CAHPS Reminders

Just a reminder that Medicare-certified home health agencies (HHAs) are responsible for the participation in the Home Health CAHPS Survey to obtain the full Annual Payment Update (APU) from the Centers for Medicare & Medicaid Services (CMS). The CY 2024 APU submission period is coming to a close on March 31, 2023, and the CY 2025 APU data collection period begins on April 1, 2023.

If you think your agency is exempt from participation in the Home Health CAHPS, please ensure that you complete a Participation Exempt Request form  in timely  manner. CMS will release the Participation Exemption Request form for CY 2025 APU after the data collection period begins. HHAs certified before April 1, 2023 should be ready to participate in HHCAHPS come April 1, 2023.

Please remember that you can be exempt from participation in the HHCAHPS Survey  if you are:

  • a newly certified HHA (please see more details below); or
  • have served 59 or fewer survey-eligible patients during the applicable year (please see more details below);

Details for the CY 2024 APU exemptions are below:

  • If an HHA received Medicare certification from CMS after April 1, 2022, the agency is considered too new to participate in the upcoming CY 2024 APU. This is a one-time exemption only, and HHAs do not need to apply for it.
  • If an HHA was certified before April 1, 2022, that HHA may only receive an exemption if it served 59 or fewer survey-eligible patients between April 1, 2021 and March 31, 2022.
  • To be exempt from participating in the HHCAHPS Survey for the CY 2024 APU, HHAs must count the number of home health patients they served between April 1, 2021 and March 31, 2022, who meet HHCAHPS survey eligibility criteria and then report that count on the Participation Exemption Request Form.
  • Please note, exemptions are active for one year only.  You must reapply if you received an exemption for CY 2023 APU and believe you are eligible for an exemption for CY 2024.

New Resources Available: BIMS, PHQ-2 to 9, and Pain Interview Cue Cards

CMS is offering a set of cue cards to assist providers in conducting the Brief Interview for Mental Status (BIMS), the Patient Health Questionnaire (PHQ-2 to 9), and the Pain Interview, as referenced in setting-specific guidance. This resource is intended to be utilized as a supplemental patient communication tool that provides a visual reference for the coding of response options. More detailed instructions regarding the use of cue cards and the administration of the BIMS in writing can be found in your setting-specific guidance manual.

The cue cards are available in the Downloads section of the HH QRP, IRF QRP, and LTCH QRP Training pages.


Prior Authorization Requests with Private Duty Nursing Services

A temporary administrative approval process for Private Duty Nursing (PDN) Prior Authorization Requests (PARs) was initiated in October 2022.

This administrative approval process will be ending on April 2, 2023, and PARs will be required for dates of service of April 3, 2023, and later for the following codes:

Kepro Provider Satisfaction Survey

Providers, please take some time  to participate in the Kepro- CO PAR Annual Provider Satisfaction Survey that will remain available until April 17, 2023.

The survey is an opportunity for providers who work with Kepro or use the Atrezzo® provider portal to provide feedback regarding Kepro services in processing prior authorization requests (PARs), customer service and timeliness.

Colorado Employers Alert- Colorado Secure Savings

It came to our attention that effective January 2023, Colorado introduced a Colorado Secure Savings Program that gives businesses a way to help employees save for their future and contribute to the retirement plan.

Once enrolled in Colorado Secure Savings, employees are able to contribute to a Roth Individual Retirement Account (IRA) directly from their paychecks and access tools to help them reach their financial goals (if employees do not want to participate in this program, they will need to officially opt out).

All Colorado employers are required by law to facilitate Colorado Secure Savings if they don’t offer a retirement plan for their employees.

This program is available at no cost to employers, but employers must provide employees with an opportunity to either participate in the program or opt out.

You can find all the necessary information regarding Colorado Secure Savings registration process at:

The registration deadlines are described as follows:

  • For employers with 5-14 workers, the deadline to register or apply for an exemption is June 30.
  • For employers with 15-49 workers, the deadline is May 15.
  • For employers with 50 or more workers, the deadline is March 15.

Please note that employers with fewer than 5 employees are exempt from participation.

If you would like to learn more about the program, please refer to the SHRM’s (Society of Human Resource Management) article at or go to the registration link above.

New Provider Web Portal URL

The Provider Web Portal and the Provider Services Call Center will be impacted by infrastructure changes beginning Friday, March 24, 2023. The Department of Health Care Policy and Finance is transitioning to a new provider portal URL.

Bookmark the New Provider Web Portal URL now for use beginning Monday, March 27, 2023

Question of the Week- Temporary CNA Certifications

As PHE is winding down, so are the associated flexibilities, waivers, and emergency rules/orders. One  of the impacted areas is the temporary CNA (T-NA) certification/license.

One of the questions we received  this week was:

Q: If an individual has a T-NA certification/license that is set to expire on 3/31/2023 and this individual is unable to schedule a skills test before the expiration date, would this individual be able to apply for the T-NA license extension?

Below is the answer we received from the Colorado Board of Nursing:

A: “As of right now, there are no extensions being offered for T-NA certifications. Per the emergency Board rules, the expiration date remains 90 days from the date of approval for new applications, with a final expiration date of 6/30/2023 if the person is issued a T-NA 90 days or less before 6/30/2023. Meaning if someone is issued [T-NA] 3/30/2023, then they’ll get a 6/30/2023 expiration; but also, someone issued 4/15/2023 would also have a 6/30/2023 expiration date, even though it is less than 90 days because 6/30/2023 is the final expiration date for temporary registrations. At this time, we do not have a date for when the Division will stop accepting T-NA applications.

The rules in place currently also still stand – if someone has already held a 90-day T-NA that has expired or they have failed either the written and/or skills exam(s), they are no longer eligible for a T-NA and must cease practice until they do pass the exams and are issued a full NA certification.”

Amity’s newsletters will be archived on Amity’s Healthcare Group website at  under the 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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Amity Healthcare Group
5600 S. Quebec St Suite 310-A
Greewood Village, CO 8011


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