Amity Healthcare Group Weekly Newsletter Issue date: January 28th, 2022

Issue date: January 28th, 2022

Here are some home health related updates for this week:AMITY’S NEWS

Education Event

If you missed our webinar, Clinical Competency: Key Step for Successful Preparation for Home Health Value-Based Purchasing, last week, please follow the link below for the recording of the webinar.

Amity Healthcare Group Consulting ServicesAmity Healthcare Group is providing continuous support to home health providers nationwide.

Our consulting services included, but not limited to:

  • Medicare Certification/Accreditation Survey preparation
  • Regulatory and clinical compliance review
  • QAPI implementation and analysis
  • Emergency Preparedness
  • COVID-19 Policies and Procedures
  • Home Health startups

For inquiries, please call 303-690-2749 or email

Skilled Nursing Competency ProgramAmity 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)
  • Pediatric Home Health Module (2 hours)

These modules are available to home health providers nationwide.

For more information, questions or registration, please go to

NATIONAL NEWSCMS Issues Guidance on the Vaccine Mandate for all States
As of January 20, 2022, all 50 states and territories are subject to the CMS vaccine mandate rule for staff. As the vaccine mandates accommodated various states in three different waives, the Centers for Medicare & Medicaid Services (CMS), Quality, Safety & Oversight (QSO) Group has issued three separate guidance memorandums (QSO-22-07, QSO-22-09, and QSO-22-11) to address compliance with the CMS Omnibus COVID-19 Health Care Staff Vaccination, Interim Final Rule.
All three memos cover the same requirements for compliance with a phased-in approach that follows 30-day, 60-day and 90-day compliance and enforcement time frames from the date that the individual memos were issued, however, the memos include different compliance dates for states, depending on which memo applies.The first memo (QSO-22-07) issued on December 28, 2021, applies to all states except:

Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Texas, Utah, West Virginia, and Wyoming.

The key compliance dates for the effected states are:

  • 30-day compliance and enforcement -January 27, 2022.
  • 60-day compliance and enforcement – February 28, 2022
  • 90-day enforcement date is March 28, 2022

Federal, state, Accreditation Organization, and CMS-contracted surveyors will begin surveying for compliance with these requirements as part of initial certification, standard recertification or reaccreditation, and complaint surveys 30 days following the issuance of this memorandum (January 27, 2022).

The second memo (QSO-22-09)  issued on January 14, 2022, applies to all of the above states except Texas.

  • 30-day compliance and enforcement -February 14, 2022.
  • 60-day compliance and enforcement – March 15, 2022
  • 90-day enforcement date is April 14, 2022

Federal, state, Accreditation Organization, and CMS-contracted surveyors will begin surveying for compliance with these requirements as part of initial certification, standard recertification or reaccreditation, and complaint surveys 30 days following the issuance of this memorandum (February 14, 2022).

The third memo (QSO-22-11) issued on January 20, 2022, applies to the state of Texas.

  • 30-day compliance and enforcement -February 22, 2022.
  • 60-day compliance and enforcement – March 21, 2022
  • 90-day enforcement date is April 20, 2022

Federal, state, Accreditation Organization, and CMS-contracted surveyors will begin surveying for compliance with these requirements as part of initial certification, standard recertification or reaccreditation, and complaint surveys 30 days following the issuance of this memorandum (February 22, 2022).

To confirm the compliance and enforcement dates for each state, CMS has developed a table with state-by-state implementation deadlines for the health care staff vaccination rule. The table is available HERE. Please consult this table to determine specific Phase 1 and Phase 2 deadlines that apply to your agency.

Please also note that CMS stated that if the 30 days or 60 days falls on a weekend or designated federal holiday, CMS will use enforcement discretion to initiate compliance assessments the next business day.

CMS has also updated the FAQ document for the CMS Omnibus COVID-19 Health Care Staff Vaccination Interim Final Rule. External FAQ IFC-6 – 1.21.22 (

In addition, CMS provided several infographics that may be helpful in navigating the mandate:

Vaccination requirements:

Vaccination requirements decision tree:

Notice of Admission – Claims Processing IssuesThe initial implementation of the Notice of Admission (NOA) did not go without glitches. It appears that the providers experienced several claims processing problems associated with NOA.  According to the National Association for Home Care and Hospice, some of the issues were caused by the Centers for Medicare Know the rules (of photography) before you break them! Ep: 46 – YouTube& Medicaid (CMS) Service systems issue, while others were related to Medicare Administrative Contractor (MAC)-specific issues.
The primary areas of concern included:

  1. Notice of Admission (NOA) processing issues
  2. Erroneous editing for reason code 31755
  3. Claims being suspended for pricing verification
Some of the fixes have been implemented and NOAs submitted this week should be processed as originally anticipated.Please note that if an NOA is late due to any of the system issues, providers should request an exceptional circumstance by utilizing the KX modifier and including a description of the issue, including the associated reason code (if applicable).

Moreover, the MACs had previously provided NOA resources which included a job aid showing exactly which fields needed to be completed for submitting the NOA. However, the job aid was for NOAs being submitted electronically only. Some of the claim fields that the job aid instructed providers to complete are not required and should not be completed when submitting the NOA via DDE (Direct Data Entry). Therefore, the MACs revised the job aid to include separate instructions for NOAs being submitted electronically and NOAs being submitted via DDE.

Home Health Quality Reporting Update
Please note that the January 2022 quarterly refresh for the Home Health Quality Reporting Program should now be available on Care Compare. For this refresh, Home Health (HH) Outcome and Assessment Information Set (OASIS) measure scores are based on three quarters of OASIS assessment data (Q3, 20; Q4, 20; Q1, 21), due to the temporary exception to the HH Quality Reporting Program (QRP) data submission requirements in response to the COVID-19 Public Health Emergency.
Please also note that the claims-based quality measures have not been updated, as CMS has decided to continue with the data freeze for claims-based measures for an additional six months. CMS is targeting the July 2022 refresh of Care Compare for the resumption of HH claims-based measure updates on Care Compare.For additional information, please see the HH QRP COVID-19 Public Reporting Tip Sheet in the downloads section of the HH Quality Reporting Training webpage.

Source: CMS

CMS Released the 1st Quarter 2022 OASIS FAQs
On January 18, 2022, CMS released Q1, 22 OASIS FAQs. To view the full list of questions and answers, please go to: Qtr_2021_QAs_January 2022_Final_508_0.pdf
Question #4 may be of a particular interest when it comes to the documentation of pain, while Questions 6-8 may be of a particular interest for providers working on the indicator of Management of Oral Medications as one of the performance improvement areas.
Provider Relief Fund (PRF) Round 2 Reporting Now Open
Just a reminder that the Health Resources and Services Administration (HRSA) opened the Provider Relief Fund (PRF) reporting portal for providers to begin entering data to submit their second period PRF reports.
Providers who received one or more General and/or Targeted PRF payments exceeding $10,000, in the aggregate, from July 1, 2020, to December 31, 2020, must report on their use of funds in Reporting Period 2.Second period PRF reports will cover PRF payments received July 1, 2020 – December 31, 2020, which include Phase 2 and Phase 3 general distributions. The deadline to use funds for Payment Period 2 was December 31, 2021.

The deadline to submit the second period report is March 31, 2022.

In addition, if you were required to report in Reporting Period 1, but did not report appropriately, you are considered to be out of compliance with the PRF Terms and Conditions and must return Payment Period 1 PRF payment(s) to HRSA.

Non-compliant providers will be excluded from receiving and/or retaining future PRF payments – including any applicable Phase 4 payments. HRSA will seek repayment on all PRF payments received between April 10, 2020 – June 30, 2020, and not reported on during Reporting Period 1.

For more information, please see Reporting Non-Compliance Fact Sheet

COLORADO NEWSEVV Pre-payment Claim Edit
There are only several days left till February 1st!Remember that effective February 1, 2022, claims without verified EVV record will deny.
For a full operational memo addressing the above matter, please go to: make sure that you have all the items completed as listed on the  action plan checklist before February 1, 2022:
Pediatric Home Health Prior Authorization RequestSome of you might have seen the headline State Reverses Course, Puts Moratorium on CNA PAR Denials and Reductions last week.  Please note that the Department of Health Care Policy & Financing has recently met with Health First Colorado (Colorado’s Medicaid program) members and families, providers, and other stakeholders about concerns related to the certified nursing assistant (CNA) pediatric long-term home health (LTHH) benefit prior authorization request (PAR) process. Based on these conversations, the Department has made the decision to temporarily pause the CNA pediatric LTHH PAR process effective November 1, 2021, until June 1, 2022, at the earliest.

Please note that only the PARs related to the CNA pediatric LTHH benefit will be paused. Pediatric LTHH Skilled Nursing Visits, Physical Therapy, Occupational Therapy, Speech Language Pathology, and Private Duty Nursing (PDN) services will continue to require a PAR. Benefits will be reinstated back to November 1, 2021, for Health First Colorado members whose PARs were denied during this time, so there is no gap in services or payment for services.

We are expecting more information about billing procedures to be communicated soon.

Chapter 26- Home Care Revision
In keeping with the statutory requirement to routinely review and update our regulations, the CDPHE conducted an extensive stakeholder process for the regulatory review of 6 CCR 1011-1, Chapter 26 – Home Care Agencies from October 2020 through September 2021.
The Board of Health adopted the updated Chapter 26 rules at the public rule-making hearing on December 15, 2021. The updated rules will take effect on February 14, 2022. Please review the updated rules attached to this message.

Amity’s Friday emails (newsletters) will be archived on Amity’s Healthcare Group website at  under Weekly Newsletter section.
Please do not hesitate to reach out for any assistance or questions via email, phone or website at 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 (look for “Subscribe to Listserv” in the top corner). If you wish to unsubscribe from this email distribution list, please email to

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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