Here are some home health related updates for this week:
AMITY’S NEWS
Amity Healthcare Group Consulting Services
Amity Healthcare Group is providing continuous support to home health providers nationwide.
Our consulting services included, but not limited to:
Skilled Nursing Competency Program
Amity Healthcare Group is offering a robust, live, instructor-led home health competency program for your skilled nursing personnel. The program includes:
NATIONAL NEWSMedicare Program Integrity Manual Revision
The Centers for Medicare & Medicaid Services (CMS) has issued Change Request (CR) 12595 to update various sections within Chapter 4 of the Medicare Program Integrity Manual, including the removal of references to Request for Anticipated Payment (RAP) suppressions.
The Change Request also adds program integrity policies around abuses with the Notice of Admission (NOA) and instructs Medicare Administrative Contractors (MACs) to identify instances where a HHA’s use of NOAs indicates potential fraud, waste or abuse. Upon identifying misuse of NOAs, the MACs are to initiate corrective action that may include, but is not limited to, education, warnings, corrective action plans, and referrals to the UPIC.
OASIS-E
As you know, OASIS -E is scheduled to go into effect on January 1, 2023. If you are curious to have a sneak peak, the updated draft of the OASIS-E All Items Instrument is now available in the downloads section of the OASIS Data Sets webpage.
Please note the instrument is not yet final. It may be used for initial training but not as a final data set for data collection until OMB approval.
Office of Management and Budget (OMB) approval is required and expected later this year. You can also find OASIS-E at Outcome Assessment Information Set Version E (OASIS-E) (cms.gov)
Care Compare
On February 10, 2022, several of the providers reported that their information was incorrectly showing on Care Compare.
Please note that CMS is aware of the issue and is in the process of updating the data on the Care Compare website. There seems to be a problem with the flow of the home health agency's information into CMS system, and as the result, it is not appearing correctly on Care Compare.
NAHC has also been in touch with CMS regarding this matter. Per NAHC, at this time, CMS does not have a timeline for implementation of a fix and a corrected display on Care Compare. NAHC will be reaching out to CMS again to ask about a correction timeframe. No further action from providers is currently required.
COLORADO NEWSColorado Employer Updates:
Employer Provided Paid Sick Leave Continues in 2022 with New Requirements
Just a reminder that as of January 1, 2022, all Colorado employers, regardless of size or industry, are required to provide “accrued” paid sick leave and public health emergency (PHE) to their employees under the Colorado Healthy Families and Workplaces Act (HFWA).
In 2021, employers with 15 or fewer employees were required to provide PHE leave but were exempt from providing accrued leave until 2022. Now, employees accrue one hour of paid sick leave per 30 hours worked, up to 48 hours per year. However, employers may allow employees to accrue leave at a faster rate and in greater amounts if they choose.
Colorado’s 80-hour COVID-related PHE leave continues as long as a COVID-related emergency remains “declared by a federal, state, or local public health agency” (C.R.S. § 8-13.3-402(9)), and both federal and state COVID-19 emergencies remain in effect. The right to HFWA COVID-related leave continues “until four weeks after” all applicable public health emergencies end or are suspended.
Please do not forget to update you Employee Handbooks and/or PTO policies to reflect the above.
Pediatric Home Health Prior Authorization Request
In our last newsletter, we notified the providers of the fact that the Colorado Department of Health Care Policy and Financing has made the decision to temporarily pause the CNA pediatric LTHH PAR process effective November 1, 2021, until June 1, 2022, at the earliest.
However, earlier today, the Home Care and Hospice Association of Colorado provided the following updates to this fluid situation (please see below).
Colorado PARs Program Modification
We know many of you have endured four or more months of difficulty with HCPF’s Prior Authorization Request, or PAR, approval process, specifically related to denials issued by the state’s new utilization manager, KEPRO.
Your association continues to push these issues aggressively with the state, and we are beginning to see progress. A few weeks after pausing the CNA Pediatric Long-Term Home Health, or PLTHH, PAR process, until June 1, 2022, HCPF yesterday announced the following:
PARs with denials for CNA, PT, OT, and SLP services issues between November 2, 2021, and January 17, 2022, will be reversed.
A suspension of PAR requirements for CNA services as well as PT, OT, and SLP in the PLTHH benefit.
A technical denial for PARs without a determination backdated to January 28, 2022.
At this time, only CNA service PAR services have been announced to resume in June. HCPF has not announced the continuation date of other services except that it would provide a minimum of 30 days' notice prior to reinstating the PAR requirements for these services.While HHAC continues to push for an efficient PAR process, these pauses are welcome news. Your association will continue to work with government representatives and other stakeholders to streamline the PAR process so that providers can assure consistency of care for our clients, the citizens of Colorado.
Thank you to Home Care and Hospice Association of Colorado for their advocacy and provider support in this matter!
To continue the topic of PARs, please note that The Department of Health Care Policy & Financing is holding a listening session for home health providers to share updates about recent changes and hear from providers about the Prior Authorization Request (PAR) process. These meeting will include an overview of feedback and common questions received from providers thus far, share an update on which of these topics have been addressed through system and other changes, and gather feedback about other technical challenges providers have had in their PAR submission process.
For those not able to attend the meeting, meeting materials and responses to frequently asked questions will be updated regularly and posted on our new CNA PAR Update web page.
Please note that individual PAR submission questions will not be addressed during this meeting. These questions should be sent to the PAR inbox at hcpf_um@state.co.us. (If you have a PAR specific question, please include actionable information including the member’s name, ID and PAR number.)
Home health and private duty nursing policy and reimbursement questions can be sent to homehealth@state.co.us.
Please do not hesitate to reach out for any assistance or questions via email, phone or website at https://amityhealthcaregroup.com/resourcesIf 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 https://amityhealthcaregroup.com (look for “Subscribe to Listserv” in the top corner). If you wish to unsubscribe from this email distribution list, please email to eg@amityhealthcaregroup.com
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