Hello, Everyone!
AMITY’S NEWS
Amity’s Healthcare Group President, Irina Gorovaya, is heading to St. Louis for 2022 NAHC Home Care and Hospice Conference and Expo. This year’s theme, Connection 4.0: Link Up!, celebrates one of the most meaningful touchstones of our industry – connection.
Please join Irina Gorovaya on Tuesday, October 25, 2022 for the following presentation:
The Art of Connecting with Telehealth in Home Health & Hospice: New Norm and Opportunities
The COVID-19 pandemic forced organizations to consider the use of telehealth in home health and hospice. The use of telehealth has further expanded with the COVID-19 emergency declaration waivers. This presentation will review the evolution of the use of telehealth in the home and address telehealth coverage and reimbursement.
Tuesday, October 25, 2022: 3:45 PM – 4:45 PM
Room: 122/123
Session Number: 801
Home Health ICD-10 Coding and Clinical Documentation Review
With OASIS-E and Home Health Value-Based Purchasing (HHVBP) coming just around the corner, take advantage of the professional assistance to ensure accurate clinical documentation, improved quality measures standing, and optimal reimbursement.
Outsourcing coding and clinical documentation review to dedicated professionals is one of the most effective strategies to strengthen and enhance documentation from regulatory, payment, and legal perspectives.
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
Are you OASIS-E ready? We are! Let Us Help You!
For more information or a free trial, please contact us at 303-690-2749 or email at ig@amityhealthcaregroup.com
NATIONAL NEWS
OUR HEARTS GO OUT TO THE PEOPLE OF PUERTO RICO AND FLORIDA
Resources and Flexibilities for Assistance
CMS announced additional resources and flexibilities in response to Hurricane Fiona in Puerto Rico. On September 20, HHS Secretary Xavier Becerra determined that a public health emergency exists in the commonwealth of Puerto Rico, retroactive to September 17. CMS is ready to help with resources and waivers to ensure hospitals and other facilities can continue to operate and provide access to care.
More Information:
- News Alert
- www.cms.gov/emergency
- Technical Assistance and Tools for Health and Emergency Management Professionals webpage
CMS announced additional resources and flexibilities in response to Hurricane Ian in Florida. On September 26, HHS Secretary Xavier Becerra determined that a public health emergency exists in the State of Florida, retroactive to September 23. CMS is ready to help with resources and waivers to ensure hospitals and other facilities can continue to operate and provide access to care.
COVID-19 News
In the previous two weeks, there were several COVID-19-related updates that effected healthcare industry, including home health. Here are the updates in the chronological order:
I) CDC’s New Guidance for Health Care Workers
On September 23, 2022, Centers for Disease Control and Prevention (CDC) issued updated guidance to several COVID-19 pandemic infection control recommendations in health care delivery settings as the result of “high levels of vaccine-and infection-induced immunity and the availability of effective treatments and prevention tools.”
The following CDC guidelines/recommendations were updated (please note that this guidance applies to all U.S. settings where healthcare is delivered, including nursing homes and home health.)
a) Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic (https://www.cdc.gov/
CDC updated:
- Recommendation that vaccination status is no longer used to inform source control, screening testing, or post-exposure recommendations
- Circumstances when use of source control is recommended
- Circumstances when universal use of personal protective equipment should be considered
- Recommendations for testing frequency to detect potential for variants with shorter incubation periods and to address the risk for false negative antigen tests in people without symptoms
- Recommendation that screening testing of asymptomatic healthcare personnel, including those in nursing homes, is at the discretion of the healthcare facility
- Recommendation that, in general, asymptomatic patients no longer require empiric use of Transmission-Based Precautions following close contact with someone with SARS-CoV-2 infection
b) Interim Guidance for Managing Healthcare Personnel with SARS-CoV-2 Infection or Exposure to SARS-CoV-2
(https://www.cdc.gov/
CDC updated:
- Recommendation for work restrictions for asymptomatic HCP with higher-risk exposure (asymptomatic HCP who have had a higher-risk exposure do not require work restriction, regardless of vaccination status, if they do not develop symptoms or test positive for SARS-CoV-2.).
Examples of when work restriction may be considered include:
- HCP is unable to be tested or wear source control as recommended for the 10 days following their exposure;
- HCP is moderately to severely immunocompromised;
- HCP cares for or works on a unit with patients who are moderately to severely immunocompromised;
Please review the updated guidance and update your current policies, as may be warranted. In addition, please note that updates are related to low COVID-19 transmission areas as well as asymptomatic HCP, so consider this as you may be intending to relieve some of the rules that were previously established.
II) Supreme Court Rejects Challenge to COVID-19 Worker Vaccination Mandate
On Monday, October 3, the United States Supreme Court rejected an appeal from ten states attorneys general, declining to hear their legal challenge to the COVID-19 health care worker vaccination mandate created by the Centers for Medicare & Medicaid Services.
CMS COVID-19 vaccination mandate remains to be in effect.
III) CMS Updates COVID-19 Guidance for Surveys
On October 4, 2022, the Centers for Medicare & Medicaid Services (CMS) revised the COVID-19 Focused Infection Control (FIC) Survey Tool and visitation restrictions for acute and continuing care (ACC) facilities through a revised QSO-21-08-NLTC memo. This memo supersedes the instructions in QSO-20-16-Hospice and QSO-20-18-HHA.
State survey agencies (SA) and accrediting organizations (AO) have returned to the existing standard survey processes and continue to assess infection prevention and control by focusing on the regulatory requirements and will not be using the Focused Infection Control (FIC) survey tool.
CMS expects health care staff and surveyors (AOs, contractors, Federal, State, and Local partners) to comply with basic infection prevention and control practices such as hand hygiene, and the use of other personal protective equipment, as appropriate for the situation (i.e., standard, contact, airborne, etc.). Surveyors should focus on the regulatory requirements for each provider and supplier type and whether the facility consistently follows processes that are based on national standards of practice and nationally recognized guidelines.
I) Report Retention Change for HHA Reports in iQIES
Effective October 4, 2022, a report retention time period will be applied to user-requested or auto-generated Home Health Agency (HHA) reports in the internet Quality Improvement and Evaluation System (iQIES). When the report retention changes are implemented, reports that are older than the pre-defined number of days will be permanently deleted by the iQIES system. The number of days the report will be available in iQIES is directly related to the date when the report was generated or made available in your My Report folder in iQIES. The report retention specifications for reports in iQIES is based upon the number of days that the reports were retained in the Certification and Survey Provider Enhanced Reporting (CASPER) application in the Quality Improvement and Evaluation System (QIES) system. Once implemented, the report cleanup will be an ongoing process and the system will automatically delete reports based upon the retention timeframes identified below.
Action Required
If you wish to permanently retain any existing reports in iQIES, you may download and save or print a copy prior to the report retention time period change. Any reports not printed or saved prior to the retention period time change will be permanently deleted if the report exceeds the retention time period.
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II) Home Health Preview Reports Available
- HHA Activity Report
- HHA Discharge
- HHA Error Summary by Agency
- HHA Roster Report
- OASIS Agency Final Validation
- OASIS Error Detail Report
- OASIS Submitter Final Validation Report
User-Requested
60 days
Yes; user can rerun these reports
HHA Quality Measure Reports
- Agency Patient-Related Characteristics (Case Mix) Report
- Tally: Agency Patient-Related Characteristics (Case Mix) Tally Report
- HHA Process Measures Report
- HHA Tally: Process Report
- Outcome Report
- HHA Tally: Outcome Report
- Potentially Avoidable Event: Patient Listing Report
- Potentially Avoidable Event Report
- HHA Review and Correct Report
User-Requested
60 days
Yes; user can rerun these reports
II) Home Health Preview Reports Available
The Home Health Preview Reports reflecting results from the Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) Survey from April 2021 through March 2022 are now available on the Home Health CAHPS website under the “For HHAs” tab.
HHAs must be logged into the website to view their report. The Preview Reports also include star ratings for those HHAs with data for 40 or more patient surveys in the 4-quarter reporting period (Care Compare will be updated in late October 2022 with the data from the Preview Report (Q2, 2021 – Q1, 2022).
III) Quality Measure Rating Threshold Changes with the October 2022 Refresh
In March 2019, CMS released memorandum QSO-19-08-NH, which outlined a plan to update the quality measure (QM) rating thresholds every six months. The plan was to increase the thresholds by 50% of the average rate of improvement in QM rating scores. For example, if there is an average rate of improvement of 2%, the QM rating thresholds would be raised 1%. Similar to setting new thresholds, this action also aims to incentivize continuous quality improvement. Additionally, it reduces the need to have larger adjustments to the thresholds in the future. Due to COVID 19, these updates were put on hold; however, we began implementing them in April 2022, and we plan to update them again with the October 2022 refresh. CMS will also release a new Five-Star Quality Rating System Technical Users’ Guide with the updated QM rating thresholds in October.
COLORADO NEWS
New Provider Participation Agreement (PPA)
The Department of Health Care Policy & Financing announced that a new Provider Participation Agreement (PPA) will go into effect on December 1, 2022. The Provider Participation Agreement (PPA) exists to define the HCPF’s expectations and outlines some of the state and federal requirements applicable to providers who perform services and submit billing, transactions, and/or data to the Colorado Medical Assistance Program.
HCPF has updated the PPA to comply with changing state and federal requirements, and to clarify the Department’s expectations of how providers should comply with those requirements. These revisions will go into effect for all currently enrolled and future providers on December 1, 2022.
No action on the provider’s part is required for the revised PPA to go into effect. It is the provider’s responsibility to review and assess the implications of any modifications to the PPA. Submission of a claim for reimbursement, continuing to provide covered services to members, or continued enrollment as a provider in the program constitutes acceptance of any modifications of the PPA.
The revised PPA can be found on the Provider Forms web page under “Provider Enrollment & Update Form.”
The Deficit Reduction
Just a reminder that pursuant to section 6032 of the Deficit Reduction Act of 2005 (DRA) any entity that receives or makes payments totaling at least $5,000,000 annually must have certain written policies and procedures in place that are readily available to all employees, contractors, or agents.
An entity includes a governmental agency, organization, unit, corporation, partnership, or other business arrangement (including any Medicaid managed care organization, irrespective of the form of business structure or arrangement by which it exists), whether for-profit or not-for-profit, which receives or makes payments, under a State plan approved under title XIX or under any waiver of such plan, totaling at least $5,000,000 annually.
If an entity furnishes items or services at more than a single location are under more than one contractual or other payment arrangement, the provisions of the DRA apply if the aggregate payments to that entity meet the $5,000,000 annual threshold. This applies whether the entity submits claims for payments using one or more provider identification or tax identification numbers.
If identified as an entity subject to the requirements of the DRA providers must:
- Establish, disseminate and maintain written policies for all of your employees, including management and the employees of any of your contractors or agents, that include detailed information about the False Claims Act established under sections 3729 through 3733 of title 31 United States Code, administrative remedies for false claims and statements established under chapter 38 of title 31, United States Code, state laws pertaining to civil or criminal penalties for false claims and statements and whistleblower protections under such laws, with respect to the role of such laws in preventing and detecting fraud, waste, and abuse in Federal health care programs (as defined in section 1128B(f)).
- Include in those written policies detailed information about your policies and procedures for detecting and preventing waste, fraud, and abuse.
- Include in any employee handbook a specific discussion of the laws described in the written policies, the rights of employees to be protected as whistleblowers and a specific discussion of your policies and procedures for detecting and preventing fraud, waste, and abuse. An employee handbook does not need to be created if one does not already exist.
Entities subject to the DRA must complete and return to the Department of Health Care Policy & Financing the DRA Declaration FFY2002 Form. Entities with multiple identified locations must send one DRA declaration with an attachment listing all NPS and service location IDs covered by the DRA declaration.
The completed DRA Declaration and the required documents listed above must be emailed to hcpf_draact2005@state.co.us no later than November 1, 2022.
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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
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Greewood Village, CO 8011