Here are some home health related updates for this week:
Thank you very much to everyone who attended “Practical Guide to Home Health Competency Program” webinar that Amity Healthcare Group co-hosted with ACHCU on June 9th, 2021.
If you missed the webinar and are interested in listening to the webinar’s recording on-demand, please go to https://register.gotowebinar.com/register/1450219966846483724?source=achcu
MACs Resume Medical Review on a Post-payment Basis
Beginning August 2020, Medicare Administrative Contractors (MACs) resumed post-payment reviews of items and services with dates of service before March 2020. On June 3, 2021, CMS announced that MACs may now begin conducting post-payment medical reviews for dates of service after March 202o. The Targeted Probe and Educate program will restart at a later time. The MACs will continue to offer detailed review decisions and education as appropriate.
NAHC is recommending for providers to carefully examine the review decision for medical reviews for the dates of service during the Public Health Emergency to ensure that appropriate PHE waivers and flexibilities were considered.
NAHC also provided a list of current post-payment review topics for each of the home health and hospice MACs as listed below. These topics may be subject to changes/updates.
|This review selects any home health claim with 2 to 6 visits and a diagnosis code of I11.0, Z46.6, J44.1, I10, J44.9, G20, I25.10, N39.0, J18.9, or I87.2 submitted with dates of service prior to March 1, 2020|
|NGS JK||Home Health PDGM|
Bill type: 32X or 33X
Reviewing claims billed under PDGM 1/1/2020 – 2/29/2020
|NGS JK||Home Health Homebound Criteria|
|Bill type: 32X or 33X|
NGS has randomly selected claims billed for the services mentioned in JK for HHH providers in the states of NEW YORK, CONNECTICUT, MASSACHUSETTS, MAINE, NEW HAMPSHIRE, VERMONT and RHODE ISLAND.
|NGS J6||Home Health PDGM|
|Bill type: 329|
Reviewing claims billed under PDGM 1/1/2020 – 2/29/2020
|NGS J6||Home Health Value Code 17 Bills|
|Bill type: 329|
Reviewing claims billed under PDGM 1/1/2019 – 2/29/2020
|Palmetto||Home Health Services for Eligibility and Medical Necessity||Review of inpatient claims submitted for home health services for eligibility and medical necessity|
Provider Relief Funds Spending Deadline
Just a quick reminder that if your Agency still has unspent Provider Relief Funds, June 30th is the last day to spend your allocated funds. Provider Relief Fund payments may be used to cover lost revenue attributable to COVID-19 or health related expenses purchased to prevent, prepare for, and respond to COVID-19, including but not limited to:
- Workforce training
- Reporting COVID-19 test results to federal, state, or local governments
- Building or constructing temporary structures for COVID-19 patient care or non-COVID-19 patients in a separate area
- Acquiring additional resources, including facilities, supplies, or staffing to expand or preserve care delivery
- Developing and staffing emergency operation centers
Note: Recipients of >$10,000 will be required to submit reports about the use of their Provider Relief Fund distribution. At this time, the targeted reporting date is July 31, 2021, however, the date may be subject to change.
CMS Revises Medicare Manual Sections for Home Health Services
CMS has issued Change Request 12222 which updates the Medicare General Information, Eligibility and Entitlement Manual, chapter 4- Physician Certification and Recertification of Services, sections 30 and 30.1 to include allowed practitioners (nurse practitioners, certified nurse specialists).
Specifically section 30.1 has been revised to include allowed practitioners where the term “physician” appears and aligns CMS policy in this manual section with the policies in the Medicare Benefit Policy Manual, Chapter 7, section 30.5.3 Who May Sign the Certification, that was revised by Change Request 12218.
These revisions clarify that the home health plan of care may be signed by another physician or allowed practitioner who is authorized by the certifying physician or certifying allowed practitioner who established the plan of care, to care for his/her patients in his/her absence.
The HHA is responsible for ensuring that the physician or allowed non-physician practitioner who signs the plan of care and recertification statement was authorized by the physician or allowed practitioner who established the plan of care and completed the certification for his/her patient in his/her absence.
Creating Opportunities Now for Necessary and Effective Care Technologies– (CONNECT) Act of 2021
The CONNECT Act was re-introduced in Congress. The Act includes a variety of provisions with direct impact to home care and hospice providers and telehealth. The provision includes the following:
- Health and Human Services (HHS) Secretarial authority to waive telehealth requirements – This would allow the HHS Secretary to waive certain requirements related to payment for telehealth services, provided that quality of care would not be adversely impacted. These waivers would need to be reassessed at least every three years to ensure quality of care remains undiminished.
- Removal of geographic requirements for telehealth.
- Expansion of originating sites to include the home.
- Waiver of telehealth requirements during public health emergencies.
- Use of telehealth services for hospice recertification – would allow for telehealth for recertification of the Medicare hospice benefit.
- Provides $3 million for audit, investigation, and other oversight activity relative to telehealth services
- Mandates the HHS Secretary to make available educational resources and training sessions of telehealth service requirements for beneficiaries and providers.
CMS Web-Based Training: From Data Elements to Quality Measures
CMS is offering a web-based training course that provides a high-level overview of how data elements within CMS patient/resident assessment instruments are used to construct quality measures (QMs) across post-acute care (PAC) settings.
The course is divided into three sections and includes interactive exercises to test your knowledge related to cross-setting QMs, how data elements feed into these cross-setting QMs, how QMs are calculated and appear on QM reports, and how to access and use this data for quality improvement (QI). This course should take 60 minutes or more to complete.
To access the course, please go to: https://pac.training/courses/Data_Elements_to_QMs/#/
Updates from Colorado Department of Labor
- Work Refusals
If you are one of the employers who experienced an instance when a job applicant either turns down your offer of work or applies for a job but fails to follow through with next steps to accept an offer of work and you believe the individual is receiving unemployment benefits, you can report this refusal to Colorado Department of Labor and Employment at cdle.colorado.gov/businesses-employers (click the Report a Job Refusal button and complete the form).
The Unemployment Insurance Division implemented new rules in May 2021 related to refusals to accept offers of work. If an individual receiving unemployment benefits fails to show up for an interview, pre-employment testing, or the first day of work without reasonable justification, they could be denied future benefits. The new rule also allows for a disqualification from benefits if claimants provide false or incorrect information during the course of the interview that would result in the applicant to be considered unqualified for the job or make it impossible to contact the applicant with a job offer.
- Colorado’s Healthy Families and Workplaces Act (HFWA)
HFWA went into effect on July 14, 2020. As per HFWA, all employers must provide paid leave for a range of health needs. That includes any time off required for “preventative care,” such as vaccination that prevents an employee from working due to a workday appointment and/or experiencing side effects afterwards. Vaccination side effects can be hard to distinguish from the wide range of possible symptoms of COVID-19 itself, and HFWA provides time off for anyone “experiencing symptoms of” COVID-19. Employers cannot require employees to obtain vaccination appointments outside work hours. For more information, please see the CDLE Division of Labor Standards and Statistics’ fact sheets on HFWA, INFOs #6B and 6C.
Incident Management and Prevention Strategies
As was noted before, the Colorado Department of Health Care Policy and Financing developed and hosted a training that reviewed case management and provider processes for Incident Management.
This training is required for all HCBS Provider Agencies. If your Provider Agency was unable to attend one of the four live training sessions hosted by the HCPF in June 2020 and has yet to access the recorded webinar training on the Department’s HCBS Waiver Critical Incident Reporting website, then your Provider Agency must do so by June 25, 2021.
To access the recorded webinar, Provider Agencies can follow this link (https://events-na11.adobeconnect.com/content/connect/c1/1100737396/en/events/event/shared/1105281446/event_landing.html?sco-id=2806100401&_charset_=utf-8) to register and access the recording or go to the HCPF HCBS Waiver Critical Incident Reporting webpage. The recording link can then be found under the “CIRs Webinars” section and is the first item listed, titled “Incident Management and Prevention Strategies Training Webinar.” Be sure your Provider Agency registers for and completes the recorded training, rather than simply accessing the webinar’s PowerPoint slides.
Every HCBS Provider Agency must complete this required training no later than June 25, 2021.
HCPF Provider Revalidation Update
The HCPF announced that due to shift in priorities related to COVID-19 Pubic Health Emergency, Providers are encouraged to submit revalidation applications according to their scheduled due date, if they are able. However, until further notice, claims will not be denied or suspended if revalidation has not been completed by the posted revalidation due date.
Applications for new enrollments and changes to existing applications have been given priority, so revalidation application processing times may be delayed for the next several months.
Only one update can be processed at a time. If providers need to make an additional update while a revalidation application is in process, contact the Provider Services Call Center.
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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)