Amity Healthcare Group Weekly Newsletter Issue date: July 23th, 2021

Issue date: July 23th, 2021

Thank you to everyone who stopped by our booth at Home Care Association of Florida 32nd Annual Conference!


The conference was a success!

For the recording of our presentation on “Practical Guide to Home Health Competency Program,” please go to:

Amity Healthcare Group Consulting Services

Amity Healthcare Group is providing continuous support to home health providers in the following areas:

  • Medicare Certification/Accreditation Survey preparation
  • Regulatory and clinical compliance review
  • QAPI implementation and analysis
  • Emergency Preparedness

If you need assistance with any of the above, please call us 303-690-2749 to schedule your 30-minute free consultation.



US Department of Health and Human Services Renews Public Health Emergency

On July 19, Secretary of Health & Human Services (HHS) renewed the Public Health Emergency (PHE) that has been in effect since January 27, 2020 due to the outbreak of COVID-19.

The Public Health Emergency is renewed effective July 20, 2021 for additional 90 days.


Home Health PEPPER

The Home Health Program for Evaluating Payment Patterns Electronic Report (PEPPER) is now available for download at the PEPPER Portal. PEPPER summarizes Medicare claims data statistics for a provider in “target areas” that may be at risk for improper Medicare payments and, as such, assists providers in identifying areas where performance falls outside the norm and payments may be at risk.

Please note, that in order to align the target areas and reports with the new risks associated with the PDGM, the following changes were instituted:

  • There are three new target areas for home health this year
  • Low comorbidity (count of periods with a secondary diagnosis that qualified as a low comorbidity adjustment paid to the HHA during the time frame)
  • High comorbidity (count of periods with a secondary diagnosis that qualified as a high comorbidity adjustment paid to the HHA during the time frame)
  • Admission Source (count of periods of admission where admission source was institutional)
  • High Therapy Utilization Episodes target area was deleted
  • Top Diagnoses Report was deleted
  • Top Therapy Episodes Report was deleted
  • Top Clinical Groups Report was added


COVID-19 Accelerated and Advance Payments: Updated FAQs


On July 8th, 2021 CMS updated FAQs related to repayment of COVID-19 accelerated and advance payments. If you got these payments, learn more about how recoupment works and how it affects your Medicare claims payment amounts.

For additional information, please also check the links below:


OSHA Emergency Temporary Standard


Just a couple of reminders/updates as related to OSHA Emergency Temporary Standard:

  1. Compliance deadlines (please make sure that your OSHA ETS plans are completed, as applicable, and met the following deadlines):
  • Majority of the standards – 7/6 /2021
  • Physical barriers, Ventilation, and Training standards –7/21/2021
    1. Effective period: ETS is effective for 6 months
    2. Stakeholder comments (period extended from July 21, 2021 to August 20, 2021).
  • Clarification on aerosol generating procedures (AGP) and nebulizer treatments: although a nebulizer treatment is an AGP, OSHA does not include nebulization in the list of AGP for the OSHA ETS because evidence of COVID-19 transmission through nebulizer treatments is inconclusive. Therefore, the requirements within the standards related to AGP do not apply to nebulizer treatments (you still may choose to consider nebulizer treatment as a high risk procedure) . The only medical procedures that are considered AGPs for the purposes of this ETS are: open suctioning of airways; sputum induction; cardiopulmonary resuscitation; endotracheal intubation and extubation; non-invasive ventilation (e.g., BiPAP, CPAP); bronchoscopy; manual ventilation; medical/surgical/ postmortem procedures using oscillating bone saws; and dental procedures involving ultrasonic scalers, high-speed dental handpieces, air/water syringes, air polishing, and air abrasion.

Survey on Home Health Aide Adequacy

As part of the 2022 proposed home health rate update rule, the Centers for Medicare & Medicaid Services (CMS) is asking for information on the adequacy of home health aide staffing. CMS is seeking information on the following questions.

  • Whether home health agencies employ or arrange for (under contract) home health aides to provide aide services;
  • The number of home health aides per home health agency (both directly employed and under contract), and whether the number has increased or decreased over the past 5–10 years;
  • The average number of aide hours per beneficiary with aide service ordered on the plan of care;
  • The effect of the public health emergency on the ability of HHAs to employ home health aides or arrange for (under contract) the provision of home health aide services.

A survey has been developed by the National Association for Home Care & Hospice (NAHC) that incorporates these questions.

To take the survey, please go to:


Review Choice Demonstration for Florida and North Carolina

Full implementation of the Home Health (HH) Review Choice Demonstration (RCD) will begin effective September 1, 2021, for HH providers in North Carolina (NC) and Florida (FL).  CMS will discontinue exercising the phased-in participation for HH RCD providers in these states. In preparation for full implementation, there will be an additional mid-cycle selection period, as detailed below:

  • Selection Period Start Date: August 1, 2021
  • Selection Period End Date: August 15, 2021
  • New Selection Effective Date: September 1, 2021

Providers who made a selection during the first selection period for Cycle 2 in April and wish to remain in the same option they previously selected do not need to take any action.

Providers who previously made a selection for Cycle 2 in April and wish to change their selection will have the ability to do so during the mid-cycle selection period. The RCD Choices available to these providers will be based on their Cycle 1 results.

Providers who did not previously make a selection for Cycle 2 and do not make a selection during this mid-cycle selection period will default to either Choice 2 (Postpayment Review) or Choice 4 (Selective Postpayment Review) based on their Cycle 1 results.

Cycle 2 for NC and FL will end on October 31, 2021.

In addition, CMS will resume applying the 25% payment reduction where applicable in all five demonstration states – Illinois, Ohio, Texas, Florida, and North Carolina.


OASIS-D1: Line-by-Line Training

The Health Facilities Education and Quality of the Health Facilities and Emergency Medical Services Division announced OASIS -D1 training  that will allow line-by-line OASIS review. The training is scheduled for Thursday, July 29, 2021 from 8:00 a.m. – 4:30 p.m.


Registration will be open until Wednesday, July 28, 2021 and will be available on the Co-Train link listed below.

OASIS-D1: Line-by-Line Review

HCPF-UM Update on PDN/Pediatric PARs

Amity Healthcare Group reached out to HCPF UM team for an update regarding PDN  and Pediatric PARs. According to UM team, “a phased-in implementation of the PDN/ Pediatric LTHH  PAR requirement is currently planned to begin on 9/1/21.” For additional updates, please continue monitoring for emails from Kepro and/or Gainwell Technologies as well as  the ColoradoPAR website ( .



Additional Resources:


There is a new Worker’s Compensation carrier in Colorado!

Network insurance services, one of the Colorado’s largest insurance brokers, has teamed up with AmTrust Financial to offer an alternative choice of worker’s compensation insurance to Colorado home health care providers.


AmTrust Financial is a leading writer of workers’ compensation insurance in the United States.

  • Highly competitive pricing in the Colorado marketplace
  • Home Health Care companies seeing 20% – 30% savings.
  • Flexible payment options and plans
  • Risk management that understands your business
  • Experienced claims specialists
  • Financial Strength – A.M. best Rating of “A-“ (Excellent)

Please see attached flyer for additional information .

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

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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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