Here are some home health related updates for this week:
Amity Healthcare Group is excited to announce our next educational event, Top Methods for Driving Employee Retention: Technology and Professional Development, on November 3, 2021.
Join ACHCU, Irina Gorovaya, Owner and President of Amity Healthcare Group, and Erin Vallier, Regional Director of Sales of AlayaCare, as we discuss the critical impact of employee training and professional development and the use of the latest technology tools on staff retention.
Presented at 11 a.m. ET on Wednesday, November 3, 2021.
Amity Healthcare Group Consulting Services
Amity Healthcare Group is providing continuous support to home health providers. We have been closely monitoring the events and information associated with COVID -19 vaccination mandates. If you need assistance with developing Policies & Procedures related to Mandatory COVID-19 Vaccination Requirements, please call 303-690-2749 or email at email@example.com
We also provide assistance with:
- Medicare Certification/Accreditation Survey preparation
- Regulatory and clinical compliance review
- QAPI implementation and analysis
- Emergency Preparedness
Do not forget to schedule your in-person and/or virtual competencies at https://amityhealthcaregroup.com/virtual-nursing-competency/
Public Health Emergency Status is Renewed Again
On October 15, the Secretary of Health & Human Services announced the renewal of the Public Health Emergency (PHE) that has been in effect since January 27, 2020, due to the outbreak of the novel coronavirus COVID-19.
The renewal of PHE goes into effect on October 18, 2021, and will last for 90 days, at which point it will either lapse or be renewed again.
Home Health Quality Reporting
CMS is providing notifications to home health agencies that were determined to be out of compliance with Quality Reporting Program (QRP) requirements for CY 2020, which will affect their CY 2022 Annual Payment Update (APU). Non-compliance notifications are being distributed by the Medicare Administrative Contractors (MACs) and were placed into HHAs’ My Reports folders in iQIES on October 8, 2021(please to be sure to check for the letter in iQIES). Facilities that receive a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, November 10, 2021.
COVID-19 Provider Funding- Phase 4
Just a reminder that the Provider Relief Fund Phase 4 application deadline is October 26, 2021 at 11:59 PM ET.
For more information about eligibility requirements, the documents and information providers will need to complete their application, and the application process for PRF Phase 4 and ARP Rural payments, visit: https://www.hrsa.gov/provider-relief/future-payments.
Quarterly OASIS FAQs
Quarterly OASIS FAQs were issued on October 19, 2021. Please take a minute to review the most recent questions and answers at https://qtso.cms.gov/providers/home-health-agency-hha-providers/reference-manuals under Quarterly Q&A section.
Home Health Research Study
The National Institutes of Health is funding a research project to be conducted by the University of Washington and the University of Pittsburg that seeks to understand how PDGM and COVID-19 has impacted home health agency operations. One activity within the study will explore home health agency administrators’ experiences of these events through one-on-one confidential phone interviews.
The National Association for Home Care & Hospice (NAHC) strongly supports the research study and urges home health agencies (HHAs) to participate in the study if contacted by the researchers.
The research team will be reaching out to home health agencies throughout the fall of 2021 and winter of 2022 to participate. Please look out for communication from the team and consider sharing your story. If you are interested in learning more about the project, please contact Amanda Shore at firstname.lastname@example.org.
The COVID-19 Vaccination Mandate Updates
On October 8, 2021, Jill Hunsaker Ryan, CDPHE Executive Director, issued the memorandum regarding mandatory staff vaccinations as set forth in the standards for hospitals and Health Facilities Chapter 2, General Licensure Standards, 6 CCR 1011-1.
For a complete memorandum, please go to: file:///C:/Users/eduar/AppData/Local/Temp/10.7.21%20Facility%20Vaccination%20Rule%20Letter.pdf
On October 18, 2021, CDPHE provided additional communication specific to the waiver of Chapter 2, Part 12 requirements for live-in caregivers of licensed Home Care Agencies. Please note that there is no waiver application necessary to utilize this exception.
According to the CDPHE, “for purposes of this waiver, a live-in caregiver is defined as an individual who is employed by a home care agency, licensed under 6 CCR 1011-1, Chapter 26, to provide care to one or more clients residing in the same household as the live-in caregiver. A live-in caregiver does not provide care to clients outside of the household.”
Under this waiver, live-in caregivers are not subject to the requirements of 6 CCR 1011-1, Chapter 2, Part 12 – COVID-19 Immunization of Employees, Direct Contractors, and Support Staff.
Agencies intending to utilize this waiver may do so under the following conditions:
- Unvaccinated live-in caregivers shall wear Personal Protective Equipment (PPE), in accordance with state and national guidelines, when in contact with other employees, direct contractors, and support staff of the home care agency, even when such contact occurs in the household.
- The agency shall maintain documentation of all employees, direct contractors, and support staff who qualify as live-in caregivers and are exempt from the regulations (unvaccinated). This documentation shall be made available to the Department upon request.
The waiver is subject to termination upon notice from the Department. Additionally, agencies must comply with all other requirements of 6 CCR 1011-1, Chapter 2 and Chapter 26, including all infection control requirements as well as vaccination requirements for agency employees and contractors who do not qualify as live-in caregivers. For agencies that utilize this waiver, compliance with the 100% staff vaccination standard required in Chapter 2, Part 12 will be calculated as follows:
100% = (total # vaccinated) + (total # medical exemptions) + (total # religious exemptions under an approved Department waiver) + (total # live-in caregivers exempt under this waiver).
If these numbers do not add up to 100% of your agency staff due to one or more religious exemptions granted by the agency, then your agency must apply for a waiver. For more information about applying for the waiver, see the Mandatory Vaccination Waiver Application Form
On October 21, 2021, the Colorado Department of Public Health and Environment announced and confirmed with Home Care and Hospice Association of Colorado Advocacy Team that they are in the process of issuing citations for facilities/agencies that had not reported employee vaccination uptake by October 15th. Citations for non-compliance can subsequently lead to penalties and potential licensing troubles for the agencies.
Private Duty Nursing and Pediatric Long-Term Home Health PARs
Just a reminder that a phased-in implementation of PDN and PLTHH PAR requirements will resume beginning on November 1, 2021.
Effective November 1, 2021, providers will submit PARs to the new utilization management (UM) vendor, Kepro, via the online PAR portal, Atrezzo. A phased-in approach of ten months has been agreed upon, so Providers do not have to submit all PARs on November 1, 2021. Providers will be responsible for submitting 10 percent of their PARs throughout the month for each phase of implementation, and providers will be responsible for deciding how to organize PAR submissions.
- November 1-November 30, 2021- 10%
- December 1-December 31, 2021- 10%
- January 1-January 30, 2022- 10%
- February 1-February 28, 2022- 10%
- March 1-March 31, 2022- 10%
- April 1-April 30, 2022- 10%
- May 1-May 31, 2022- 10%
- June 1-June 30, 2022- 10%
- July 1-July 31, 2022- 10%
- August 1-August 30, 2022-10%
The following will continue:
- A 60-day administrative approval will be issues prior to any PAR denial going into effect. The 60-day administrative approval will begin from the start date of services on the denied PAR.
- Please note: The member’s appeal rights begin 60 days from the date of the PAR determination letter, not the date that the denial goes into effect.
- Continuation of benefits for any member appeal will be issued.
- Step down process for PDN denial that reduce services by 30% or more will continue.
- Weekly reports will be sent to Regional Accountable Entities (RAEs) of any denials to allow for care coordination.
Please note: While the Utilization Management vendor has changed, the policy for these two benefits remained unchanged. Providers are required to submit the Pediatric Assessment tool for PLTHH PARs, and the PDN Acuity Tool for PDN PARs.
- Recorded benefit-specific training sessions for PDN and PLTHH are available on the Kepro Provider Training Information web page. Provider training information updates will be posted on the ColoradoPAR Program web page.
- PDN and PLTHH providers are required by the Department to watch recorded Atrezzo provider portal training videos and PDN or PLTHH benefit-specific training prior to submitting a PAR for PDN or PLTHH services.
- Contact Kepro at (720) 689-6340 or email@example.com for any questions regarding PARs. Email firstname.lastname@example.org for issues registering or accessing provider training.
- Contact the Department at hcpf_UM@state.co.us with any escalated questions or concerns regarding PARs. For questions about specific Members and/or cases, please be sure to include the Case number and/or PAR number in the initial email.
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Please do not hesitate to reach out for any assistance or questions via email, phone or website at https://amityhealthcaregroup.com/resources/
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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)