Bulletin: April 7th, 2020

April 7th, 2020

SNAP SHOT

HOSPICE and HOME HEALTH: CDC Issues Guidance on Strategies to Optimize PPE & Equipment, NAHC Forum of States Listserve, April 2, 2020 – On March 31, the Centers for Disease Control and Prevention (CDC) issues guidance to health care professionals on Decontamination and Reuse of Filtering Facepiece Respirators using Contingency and Crisis Capacity Strategies. While disposable filtering facepiece respirators are not approved for routine decontamination and reuse as a standard of care, such action may be necessary as a crisis capacity strategy. This guidance discusses crisis standards of care for such decontamination and information regarding various methods for decontamination. We have had questions about use of KN-95 masks in lieu of N-95 masks. On April 5, the FDA issued guidance which can be found here.

HOSPICE and HOME HEALTH: NAHC Asks CMS/HHS for Reg Flexibility to Fight COVID-19, NAHC Report, April 3, 2020 – The National Association for Home Care & Hospice (NAHC) has made a series of requests to the Centers for Medicare & Medicaid Services (CMS) for regulatory action designed to enable home health and hospice to fulfill its potential as the health care setting most suited to stopping the spread of the novel coronavirus COVID-19 while continuing to treat needy patients.

HOSPICE and HOME HEALTH: Rising Employer Insurance Costs Due to COVID-19 Could Hit Hospices and Home Health, Hospice News, April 6, 2020

HOSPICE: CMS Waives Hospcie Rules During Pandemic, Further Expands Telehealth, Hospice News, April 1, 2020--The U.S. Centers for Medicare & Medicaid Services (CMS) has waived a number of hospice regulations, including temporarily removing the requirement that a nurse conduct a home visit at least every two weeks and expanding the allowable use of telehealth.

HOME HEALTH and HOSPICE: Beneficiary Notice Delivery Guidance in Light of COVID-19, CMS List Serve, March 26, 2020 – In light of concerns related to COVID-19, current notice delivery instructions provide flexibilities for delivering notices to beneficiaries in isolation.

HOME HEALTH and HOSPICE: COVID-19 Summary for Home Health and Hospice, NAHC List Serve, March 20, 2020 — NAHC has created a summary relevant information impacting home health agencies and hospices related to the COVID19 pandemic. The information is broken down into three categories: Patients, Home Health and Hospice Staff, and Regulatory and Operations.

HOME HEALTH and HOSPICE: CMS Provides Financial Relief for Medicare Providers – UPDATED, VonLehman, April 7, 2020 – On March 28, 2020, the Centers for Medicare and Medicaid Services (CMS), recognizing providers’ need for resources to combat COVID-19, issued a release announcing an expansion of its accelerated and advance payment program for Medicare participating health care providers and suppliers. On April 3, 2020, the request forms were changed by the MACs and posted to their websites.

>>> PDGM UPDATES –

HOME HEALTH: Home Health Data Report – March 2020, BKD, CPA & Advisors – This report provides key performance indicators (KPIs) to help assess performance under the home health Medicare Patient Driven Groupings Model (PDGM) compared to the Prospective Payment System (PPS). All data was compiled by BKD, LLP using the Centers for Medicare and Medicaid Services (CMS) claims-OASIS limited data set from the 2020 final payment rule, which is composed of 2018 PPS claims and OASIS data repriced according to PDGM methodology. This data does not consider CMS behavior adjustments.

>>>RCD UPDATES –

CANCELLED – OCHCH WEEKLY PDGM/RCD CALL - FRIDAY, April 10, 2020

If you have PDGM or RCD QUESTIONS PLEASE SEND THEM TO helpdesk@ochch.org

Use PDGM or RCD as the subject title.

If you need OCHCH to contact Palmetto GBA regarding a PCR NON-AFFIRMATION,
Please e-mail a short description and the UTN and your provider number.
DO NOT e-mail any info that could be non-compliant with the HIPAA regulations

Please check out the toolkits for PDGM and also RCD!

INFORMATION from the RCD ONLY Call on April 3, 2020:
OCHCH RCD Update: April 3rd, 2020;
RCD for Ohios Home Health Services Has Been PAUSED

Our Take

HOME HEALTH: RCD pause

By Kathy Royer, RN, BA, MBA, DMin, CHPN, CHPCA, CEHCH and
Beth Foster, RN, BA, CPHQ, CEHCH

The impact of the COVID-19 outbreak has resulted in a number of regulatory changes for Home Health and Hospice providers. Among the changes is the ability for Home Health providers to choose to pause Pre Claim Review (PCR) during the Public Health Emergency (PHE). This change was effective March 29, 2020. We have had a number of questions asking for clarity about the March 29^th date.

Question:
I received the following question and need clarification please: “I would still like to verify that the dates of services don't need to be March 29th and after. When you read the last question on page 2, it seems clear that it is saying "Claims for services FURNISHED on or after March 29th". Please let me know what you think.”

The following is from: 2019-Novel Coronavirus (COVID-19) Provider Burden Relief, Frequently Asked Questions (FAQs) March 2020:
”Claims for home health services furnished on or after March 29, 2020 and before the end of the PHE for the COVID-19 pandemic in these states (Illinois, Ohio, and Texas) will not be subject to the review choices made by the home health agency under the demonstration.”

My question -- Is it the claims with covered services that were provided prior to March 29, 2020? Or the HHA providers must wait until they bill for the services that on or after March 29^th?

Answer:
It is our understanding that this verbiage means that any claims that are submitted on or after March 29, 2020, are not subjected to the demonstration. This is submission date driven and not date of service driven. At this time, it is set to expire when the PHE is over. If we hear otherwise, we will let you know. I hope this clarifies the question, if not please let me know.

OCHCH wants Home Health providers to know if they choose to pause PCR during the PHE, they can submit the final claim for payment without the UTN. However, after the PHE is over, PCR claims submitted for final payment without the UTN, will be ADR’d at 100%.

Kathy Royer, RN, BA, MBA, DMin, CHPN, CHPCA, CEHCH and Beth Foster, RN, BA, CPHQ, CEHCH

HelpDesk Question of the Week

HOME HEALTH: Home Health Initial Assessment

There has been some confusion around this.

Question: What is the difference between the initial assessment and the comprehensive assessment?

Answer: Many agencies do their initial assessment and the start of care comprehensive assessment together. Actually the initial and start of care assessments are different types of visits. The Initial visit is when the clinician makes the determination if the patient is eligible for Home Health, this can now be done via telehealth.

A registered nurse (or the appropriate rehabilitation skilled professional, if therapy only) must conduct an initial assessment visit to determine the immediate skilled care and support needs of the patient; and, for Medicare patients, to determine eligibility for the Medicare home health benefit, including homebound status. The initial assessment visit must be held either within 48 hours of referral, or within 48 hours of the patient's return home, or on the physician-ordered start of care date.

Reminder: The SOC date is the date of the first qualifying skilled visit.

Regulatory & Policy Digest

HOME HEALTH and HOSPICE: Special Open Door Forum addressing Telehealth in Medicare during COVID-19. 1:30-2:30 PM ET on Wednesday, April 8, 2020.

HOME HEALTH and HOSPICE: CMS Includes New Waivers Related to Stark Law in COVID-19 Regs, NAHC Report, April 3, 2020 – The COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers recently released by the Centers for Medicare & Medicaid Services (CMS), includes a blanket waiver of sanctions for some sections of the Stark Law. The blanket waivers may be used now without notifying CMS. Individual waivers of sanctions under section 1877(g) of the Act, the “Stark Law”, may be granted upon request.

HOSPICE: Reason Code C7010 Job Aid, Palmetto GBA List Serve, April 7, 2020 – Reason code C7010 is generated when records show that the beneficiary has elected the Medicare hospice benefit and services billed as being related to the terminal diagnosis by a non-hospice provider. This job aid includes information on how to resubmit clams that receive Reason Code C7010. Please review and share this information with your staff.

HOSPICE: Hospice Provider Preview Reports: Review Your Data by April 13, CMS MLN Connects, April 2, 2020 – Two reports are available in your Certification and Survey Provider Enhanced Reports (CASPER) non-validation reports folder:

Hospice provider preview report: Review Hospice Item Set (HIS) quality measure results from the third quarter of 2018 to the second quarter of 2019
Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS®) provider preview report: Review facility-level CAHPS survey results from the third quarter of 2017 to the second quarter of 2019

Review your results by April 13, prior to public display on the Hospice Compare website in May. If you believe the denominator or other HIS quality metric is inaccurate or if there are errors in the results from the CAHPS survey data, request a CMS review.
For More Information

Upcoming Education & Events

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News Clips & Links

HOME HEALTH and HOSPICE: Molina Healthcare of Ohio Announces $150,000 Commitment to Fund Purchase of PPE,Molina news release, April 2, 2020

HOME HEALTH and HOSPICE: COVID-19 Update: Sites Selected for Enhanced Hospital Capacity; Ohio National Guard to Assist Federal Prison; Dispute Resolution Commission Now Active, Ohio, April 6, 2020

HOME HEALTH and HOSPICE: Ohio health workers to test oral antiviral spray for prevention of coronavirus infection, The Columbus Dispatch, April 2, 2020

HOME HEALTH and HOSPICE: U.S. home healthcare industry warns of possible 'collapse', Reuters’ Business News, March 26, 2020

HOME HEALTH and HOSPICE: CMS Accelerates Medicare Payments During COVID-19, Hospice News, April 1, 2020

PALLIATIVE CARE: Palliative Care Providers Mobilize During COVID-19, Hospice News, April 6, 2020

HOSPICE: Hospice Board, Executive Coordination Essential to COVID-19 Response, Hospice News, April 1, 2020

HOSPICE: Older Americans Act Reauthorized with Funds for Hospice Family Caregivers, Social Determinants, Hospice News, April 1, 2020

HOSPICE: Advance Care Planning Remains a Priority During COVID-19, Hopsice News, April 3, 2020

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