Bulletin: January 28th, 2020

January 28th, 2020



ODH Shared Home Health and Hospice Data, and Updated SOM
OCHCH staff, Joe Russell, Beth Foster, and Kathy Royer attended a recent Ohio Department of Health (ODH) Non Long-Term Care Provider Meeting on January 15, 2020. We discussed the release of the 2019 2nd Quarter Home Health and Hospice top deficiencies that are included in the following documents: Also, ODH shared the CMS Burden Reduction and Discharge Planning Final Rules Guidance and Process memorandum, QSO-20-07-ALL. This policy memorandum provides guidance to the CMS Regional Offices (ROs), the State Survey Agencies (SAs) and the Accrediting Organizations (AOs) regarding the changes to the regulations and CMS’ approach for updating the State Operations Manual (SOM) and applicable surveyor systems.
  • SOM Appendix B – Guidance for Surveyors: Home Health Agencies (HHAs) starts on Page 127
  • SOM Appendix M - Guidance for Surveyors: Hospice starts on Page 305.
  • SOM Appendix Z- Emergency Preparedness for All Provider and Certified Supplier Types Interpretive Guidance starts on Page 641.
The list of the top survey defiencies and the SOMs are great tools for Home Health and Hospice agencies to prepare for surveys and see what surveyors are looking for.

HOME HEALTH: January 2020 CMS Quarterly OASIS Q&As released on January 21, 2020. Pages 1-3 address data collection that is affected by PDGM.
Home Health and Hospice: HHS Warns of Potential Cyber Threat to Health Care Entities, NAHC Report, Janaury 24, 2020Below is an announcement from the HHS Office for Civil Rights related to a cyber threat potentially impacting healthcare and public health (HPH) sector entities.The purpose of the bulletin is to notify healthcare providers of a number of vulnerabilities identified in Microsoft Windows operating systems which if not addressed, pose significant threat to the environment.
HOME HEALTH and HOSPICE: CMS Plans Complete Redesign of Compare Websites for Home Health, Hospice, NAHC Report, January 23, 2020 – The Centers for Medicare & Medicaid Services (CMS) plans to launch a new Medicare Care Compare on Medicare.gov to combine and standardize the eight existing Compare tools, including those for home health and hospice.
The new Compare tool, which CMS plans to launch in Spring 2020, will combine the eight existing and separate Compare tools for Home Health, Hospice, Hospital, Nursing Home, Dialysis Facility, Long-Term Care Hospital, Inpatient Rehabilitation Facility, and Physician. Currently, these eight Compare tools are among the most popular and utilized sections of the Medicare.gov website.

HOME HEALTH: REMINDER: iQIES Issues Still Occurring – Call Keith Weaver, Ohio Dept. of Health Automation specialist, at 1-614-995-7898 or e-mail him keith.weaver@odh.ohio.gov.  Keith will assist you by trouble shooting. If he is unable to assist you he will find someone that can!
Keep Beth Foster informed of any issues with iQIES. The OCHCH Regulatory Department (Kathy Royer and Foster) are ready to assist you! PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, iQIES.

>>>RCD UPDATES –                                                                                                                  

Next OCHCH Weekly RCD Conference Call - Friday, JANUARY 31, 2020 at 10am!
DON’T MISS THIS OPPORTUNITY!! Please mark your calendars for EVERY FRIDAY @ 10am. The calls will last no more than an hour.
Call-in info for 2020 will remain the same:
Login - https://web.telspan.com/go/ochch/ochchpdgm
Dial: 888-392-4564
Passcode: 7896828#
If you have trouble getting on the Call – PLEASE CALL OCHCH 1-614-885-0434 Ext.206, or e-mail ryan@ochch.org
ATTENTION: Check out the updated RCD Toolkit located in the members’ section of the OCHCH site. Just login to “My Profile” and in the left column under “HELP DESK ONLINE” click on “RCD Toolkit.”
The links to the RCD Call Recordings for the months of November, December, and January are available in the RCD Toolkit.  
Dial 855-696-0705
Press “0” at the main menu
Press “0” again
Press “3” for HHH
Press “1” for an RCD agent
REMINDER: All RCD provider questions must go through the Palmetto GBA Provider Contact Center (PCC) at 855-696-0705. However, if your questions are not being answered, you are not receiving a call back in a timely manner, or you need assistance to contact Palmetto GBA, PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, “RCD” and include the UTNs, OR call 614-885-0434 Ext 209.
Monthly Review Choice Demonstration (RCD) Provider Teleconference Schedule – Next date is February 5, 2020.
Quarterly Review Choice Demonstration (RCD) Medical Review Teleconference Schedule – Next date is March 11, 2020.
THIS IS THE FINAL>>> Palmetto GBA CLARIFICATION of UTN received prior to Jan. 1, 2020 for a SOC or Recert
 For all 60-day episodes that started prior to 1/1/2020, a single UTN would provide for the full 60 days. It doesn’t matter how far the episode goes into 2020, as long as it started in 2019.
For all 30-day periods that start after 1/1/2020, a UTN is required for each 30-day period.
For example, the start of a new 60-day episode was on 12/28/19, a PCR request should be submitted for the 60 days. Once affirmed, the agency would receive a UTN for the full 60-day billing period. No additional UTNs are needed for this 60-day billing period, which ends on 2/25/20. The claim is billed for the full 60 days with the single UTN.
If the patient is recertified for 2/26/20 and on, a PCR request and UTN is required for each subsequent 30-day period.
How to Retrieve Your RCD Affirmation RateCLICK HERE

eRCD is Now Active - eRCD is a new feature on the Provider Dashboard within eServices that provides you with the ability to monitor your Review Choice Demonstration (RCD) results. You will enjoy features such as your RCD affirmation or claim approval rate, and current Additional Documentation Request (ADR) and Pre-Claim Review (PCR) decisions.


OCHCH Weekly PDGM Conference Call is today, Tuesday, January 28, 2020 at 3pm.
Next week it will be on Tuesday, February 4, 2020 at 3pm.
DON’T MISS THIS OPPORTUNITY!! Please mark your calendars for EVERY TUESDAY @ 3pm. The calls will last no more than an hour.
Login – https://web.telspan.com/go/ochch/weeklypdgm
Dial: 888-392-4564
Enter: 1115130#
**This PDGM login/call-in information will be the same for each week**
If you have trouble getting on the Call – PLEASE CALL OCHCH 1-614-885-0434 Ext.206, or e-mail ryan@ochch.org
Check out the updated PDGM Toolkit located in the members’ section of the OCHCH site. Just login to “My Profile” and in the left column under “HELP DESK ONLINE” click on “PDGM Toolkit.”

If you have questions PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, “PDGM,” OR call 614-885-0434 Ext 209.
OCHCH has a number of recordings available on our website of previous PDGM education webinars for your purchase or access. Moving forward OCHCH is committed to bringing you continued education on the implementation of PDGM and its impacts on our industry.
The links to the PDGM Call Recordings for the month of December and January are available in the PDGM TOOLKIT.
The Home Health FAQs - Home Health Patient-Driven Groupings Model (PDGM) – (January 6th, 2020- link) was posted to the PDGM TOOLKIT.
Patient-Driven Groupings Model (PDGM) Grouping Tool Help Document link – The purpose of the grouping tool Excel file is to help users understand how the payment grouping parameters, which are part of the PDGM, would be used to determine case-mix assignments that are part of the payment calculation under the Home Health Prospective Payment System (HH PPS).   

Payments and Payment Adjustments under the Patient-Driven Groupings Model, Palmetto GBA – This article provides information on the implementation of the new Home Health Prospective Payment System (HH PPS) case-mix adjustment methodology named the Patient-Driven Groupings Model (PDGM). The PDGM will be implemented for home health periods of care starting on and after January 1, 2020.  This MLN Matters Number: SE19028 is a very comprehensive tool to share with staff so they develop a better understanding of the PDGM. 
CMS Quarterly OASIS Q&As Update on Discharging, January 16, 2020 – Note: This Q&A supersedes October 2019 CMS Quarterly Q&A #6.
OASIS Considerations for Medicare PDGM Patients – This document provides PDGM transition guidance for OASIS time points.
October 2019 CMS Quarterly OASIS Q&As – Please note that guidance Q&As related to PDGM will become effective with assessments with a M0090 date of January 1, 2020 or later. Pages 1 through 10 address PDGM related questions. 

UPDATED INFO: CMS Updates Claims Processing Manual, NAHC Report, January 14, 2020 – CMS has again updated Change Request (CR) 11081 – Home Health (HH) Patient-Driven Groupings Model (PDGM) – Split Implementation through Transmittal 4489. This CR has been updated more than once since its original publication in early 2019. This most recent update corrects the Request for Anticipated Payment (RAP) payment percentage in the Policy section of the Business Requirement form. The correction was necessary because the previous release did not update the RAP percentages with the 2020 Home Health final rule update effective January 1, 2020 which reduced the RAP percentage to 20 percent. All other information remains the same.

UPDATED INFO: Home Health (HH) Patient-Driven Groupings Model (PDGM) - Spilt Implementation, Palmetto GBA  - Change Request (CR) 11081 effectuates the policies of the Patient-Driven Groupings Model (PDGM) as described in the November 2018 home health (HH) final rule. CMS revised the article on January 14, 2020, to reflect a revised CR11081 that CMS issued on January 9. CMS revised the CR to correct the RAP payment percentage in the Policy section of the Business Requirement form in the CR. CMS revised the article to reflect the same change in the Background Section of the article. Please make sure your billing staff is aware of these changes.

Our Take

EVV Updates:

By Alexandra Weingarth, Policy and Advocacy Director

EVV Updates:
There is a lot of information, so let’s dive right into it:
Good faith exemption for Electronic Visit Verification
What does this mean? The 21st Century Cures act required Ohio’s Medicaid program to implement EVV for all personal care by January 1st 2020, however, Ohio was not ready to be fully compliant with the system. So essentially, ODM asked for an “extension.”  The implementation date for all personal care services is January 1st 2021- we must be up and ready by that date to maintain all federal funding levels.
Alternate System Demo
ODM shared that only 5 alternative vendors have successfully completed and passed the new demonstration requirement out of the 18 that have been tested (42 demos have been scheduled). Reminder, if you have an alternate EVV vendor, they must schedule a demonstration with ODM, Sandata, the provider, and the vendor. This is a requirement! If you do not complete the demonstration requirement and the Sandata portion of the process before July 1, 2020, you WILL be required to transition to Sandata until you’re alternative vendor has completed the certification requirements. Please see the attached slides on slide 7 that identify the common issues ODM has documented during the demos.

Device Swap
The EVV devices in your patient’s home may not have the newest software required. There are an estimated 3,200 providers that have devices that will need swapped out. Please continue using the old device until the replacement is received in the individual’s home.  ODM has estimated that recoupment process will take about 6 months. Please see slide 12 for how the maintenance swap process will work.
Phase 3
In the fall of 2020, ODM will start training for Phase 3. The services that are included in Phase 3 are:
Participant directed aide services (including): My Care, ODA, DoDD, Ohio Home Care Waiver and
Home Health Therapies: Physical Therapy, Occupational Therapy and Speech Therapy
Phase 3 will work similarly to Phase 2. If you are already using the EVV system, ODM will provide the “bridge training” focusing on the new functionality. However, there will be a more focused training for the participant directed services. Please see slide 23-26 if you need more information.  ODM will continue to provide us with monthly updates which we will then share with you.
As always, if you have any questions, please reach out at alex@ochch.org.

Click here to get the EVV slide Presentation

Alexandra Weingarth

HelpDesk Question of the Week


HOSPICE: Continuous Care

 Question: Our hospice is working to make sure we are offering Continuous Care when needed, however also making sure we are compliant with the reg. We are often being challenged specifically by AL’s that other hospices would offer CC in a situation where we don’t feel it is appropriate.
I have read the COP multiple times including the compliance tip sheet sent from NHCPO and there is a lot of what I call “gray” areas. For example we are being told other hospices in the area are starting CC in an AL or in a home when the client is on comfort meds Q4 hours or less scheduled to maintain comfort. I can see if there are adjustments needing to be made but if we believe the Q4h is providing the comfort and symptoms are managed, would the CC case stop?
We are just struggling on completing in this area. We want to offer the right LOC and of course be compliant when doing so. We want to offer CC more often if maybe we are missing opportunities by misunderstanding the COP.
We are also not understanding how other hospice’s are offering this in the cbus area in times we wouldn’t agree the case is CC.
Anything you can offer on this topic would be great as we are working on building our CC program as our hospice is growing and we feel the need is increasing. Thank you!
Answer: In my previous organizations I remember the challenge of the AL asking for continuous care and after our case manager assessed the patient we determined it was not the appropriate level of care.  Often the AL would say they would use a competing hospice because they would do continuous care.
The bottom line is Medicare considers Hospice to be the professional manager of the Hospice patient’s care, which means Hospice  determines what is the appropriate level of care.  Also currently there is a great deal of scrutiny with utilization of Continuous Care and General In Patient.  Medicare is monitoring for Hospice programs that do 0 cases of CC or GIP.  Medicare is also monitoring Hospices who do a high volume of CC or GIP.  In either case of 0 volume or high volume, the agency is at risk of being placed in TPE.
It can be difficult for staff to recognize situations in which the patient would benefit from being placed on a higher level of care.  Some CC or GIP examples are the patient requires frequent medication adjustment to manage a symptom, or if the symptom cannot be controlled in the patients present setting.  In my previous setting we did weekly case studies of a patient who had symptom control issues.  I found the case studies to be a great way to raise awareness for staff about the higher levels of care.
In my former agencies as an  administrator I wanted to always do the right (ethical) thing for my patients and always believed those who do not do what is the ‘right’ thing would eventually be held accountable.
I think knowing when to utilize GIP and CC can seem ‘gray’ at times but over time one can have more confidence in the decision of when to provide this level of care and when it is not appropriate.



Regulatory & Policy Digest


HOSPICE: CMS Medical Review Hot Topic: Targeted Probe and Educate to be held March 2, 2020.

HOME HEALTH and HOSPICE: OSHA Injury, Illness Report Due March 2, NAHC Report, January 21, 2020March 2, 2020, is the deadline for electronically reporting your Occupational Safety and Health Administration (OSHA) Form 300A data for calendar year 2019. Collection began January 2, 2020.

OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule. See previous NAHC Report coverage here.
Remember, not all establishments are covered by this requirement. To review which establishments need to provide their data, click here.


HOSPICE and HOME HEALTH: Update to Medicare Claims Processing Manual, Chapter 24, Section 90,  Palmetto GBA

HOSPICE and HOME HEALTH: February 2020 JM Home Health and Hospice Medicare Advisory, Palmetto GBA 

HOSPICE and HOME HEALTH: The MAC Medical Review Feature in eServices Is Now Available , Palmetto GBA 

HOME HEALTH: Resolved: Claim Adjustments for Home Health A/B MAC Shift of Payments, Palmetto GBA

HOSPICE and HOME HEALTH: Hospice and Home Health Claims Processing Issues Log, Palmetto GBA

Upcoming Education & Events


For Upcoming webinars, conferences, workshops and events click HERE

The dates are set for the 2020 Annual Conference!  Get extra socks, because we are going to knock them off again!

Save the Date: September 22nd and 23rd at the Hyatt Regency in Columbus, Ohio!

News Clips & Links

HOSPICE: Hospice Expected to Grow in 2020, Increase Focus on Social Determinants, Hospice News, January 27, 2020
HOSPICE: Pet Programs Diversify Hospice Services and Boost Volunteerism, Hospice News, January 22, 2020
HOSPICE: NPR Explores the Toll of Caregiving on Hospice Patient Families, Hospice News, Janaury 22, 2020
PALLIATIVE CARE and HOSPICE: New Jersey Legislation to Expand Hospice and Palliative Care, Hospice News, January 27, 2020

Ohio Council for Home Care & Hospice  1105 Schrock Rd., Suite 120, Columbus, OH 43229
(614) 885-0434   www.ochch.org