Bulletin: April 28th, 2020

April 28th, 2020


COVID-19 Resource Center

HOME HEALTH and HOSPICE: CMS PHE Survey ActivityDuring the Public Health Emergency, CMS has refocused its survey activities. CMS is conducting focused infection control surveys across the nation and is at times are doing the surveys remotely. 
HOME HEALTH and HOSPICE: CMS Reevaluates Accelerated Payment Program and Suspends Advance Payment Program, CMS List Serve, April 25, 2020 – On April 25th CMS announced that it is reevaluating the amounts that will be paid under its Accelerated Payment Program and suspending its Advance Payment Program to Part B suppliers effective immediately. The agency made this announcement following the successful payment of over $100 billion to healthcare providers and suppliers through these programs and in light of the $175 billion recently appropriated for healthcare provider relief payments.
HOME HEALTH and HOSPICE: Telehealth Resources, NHPCO NewsBriefs, April 24, 2020 A new website, Telehealth.HHS.gov  went live April 23, 2020 to provide information about the latest federal efforts to support and promote telehealth services. It provides helpful information about telemedicine and links to tools and resources for practitioners. Accompanying the release, the Surgeon General released a blog directed to healthcare providers, urging them to join the telehealth revolution. He notes that healthcare providers have a unique opportunity to integrate telemedicine into their practice.
HOME HEALTH and HOSPICE: COVID-19 Workforce Virtual Toolkit Resources for Healthcare Decision-Makers Responding to COVID-19 Workforce Concerns, NHPCO News Briefs, April 24, 2020 This collection provides a curated set of resources and tools for decision-makers managing healthcare workforce challenges in response to the COVID-19 emergency.
HOSPICE: CMS Holds Home Health and Hospice Stakeholder Call, NHPCO NewsBriefs, April 22, 2020 – On April 21, CMS held a Home Health and Hospice Stakeholder Call, in which they answered two questions that many hospice providers have asked in recent days.
HOME HEALTH: CMS Revises Memo on Infection Control and Prevention of COVID-19, NAHC Report, April 23, 2020 – The Quality, Safety, and Oversight Group of the Centers for Medicare & Medicaid Services (CMS) revised a memo addressing guidance for infection control and prevention concerning COVID-19 in home health agencies (HHAs) and religious nonmedical healthcare institutions (RNHIs). The memo was originally released on March 10, 2020 and was revised April 23, 2020. Even though it is titled for home health agencies and RNHIs, there is additional information about CMS waivers and regulations, CDC guidance for optimizing personal protective equipment and return to work criteria for healthcare personnel with confirmed or suspected COVID-19. Please read more regarding HHA access to residents in assisted living and independent living facilities.

>>>RCD/PDGM UPDATES –                                                                                                                  

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!

>>>RCD UPDATES –                                                                                                                  

We Are Going Green with RCD Cycle Results eLetters, Palmetto GBA – Palmetto GBA is going green with RCD Cycle Results eLetters. We will send home health agencies their RCD Cycle Results via eLetter in eServices. Please review and share with your staff.

RCD Tip: Using the Correct Provider Transaction Access Number (PTAN), Palmetto GBA – If you are a part of a Home Health Agency (HHA) with more than one location and multiple PTANs, please make sure you are using the correct PTAN when submitting Pre-claim Review (PCR) requests.

RCD for Ohio’s Home Health Services Has Been PAUSED
Ohio Providers Transition to Review Choice Demonstration (RCD) Cycle Two, Palmetto GBABeginning May 1, 2020, you will be able to choose the next round’s review option. Typically, the selection period is open for a two-week period. Due to the current Public Health Emergency (PHE) related to COVID-19, the last day to make a selection has not yet been determined. Palmetto GBA will announce the last day to make a selection as soon as possible on our website and via email update. If you are not signed up for the Palmetto GBA email updates, please visit https://tinyurl.com/GetListserv to sign up

Don’t Wait - Register NOW! WEBINAR – “Ohio Providers Transition to Review Choice Demonstration (RCD) Cycle Two by Palmetto GBA, Friday, May 1, 2020 – 10am-11:30am

Our Take

ODM Developing an Emergency Rule so NPs, CNSs, & PAs Can Order Home Health Services!
By Beth Foster, RN, BA, CPHQ, CEHCH

  • NPs, CNSs, & PAs Readiness check off list:
    • Within scope of practices
    • Approved for Medicare Beneficiaries
    • Education on Medicare Certified Home Health Agency Coverage Regulations: OCHCH presented Webinar to NPs on April 22 
      • Certifying Patients for the Medicare Home Health Benefit” (MLN SE1436)
  • Plan to finish checkoff list:
    • GOOD NEWS: Ohio Department of Medicaid (ODM) is addressing Plans of Care and Certifying/Recertifying Patient Eligibility by NPs, CNSs, and PAs in an emergency rule package that is being prepared!!! Stay Tuned!
    • Provide more education webinars with NPs, CNSs, and PAs
    • Contact other payer sources to determine if accepting orders from Non-Physician Practioners (NPPs) & create a list to share with members;
    • HHAs should ask other payers if they are following the Medicare coverage regulations to allow Nurse Practitioner, Clinical Nurse Specialist, and Physician Assistant order home health services, and establish and manage the Plan of Care.

At this time, this means NPPs could at least start with individuals on Medicare and other payer sources in having the Primary Care Practitioners (PCP = NP, CNS, PA) certify eligibility for the home health benefits and to establish and manage the Plan of Care. 

Right now this is a temporary change, however this will be permanent as soon as CMS develops rules/regulations that are required to be in place within 6 months or less from the passing of the CARES Act.

OCHCH will share the emergency rule as soon as we receive it!


By Beth Foster, RN, BA, CPHQ, CEHCH

HelpDesk Question of the Week

Question: Is it true that OTs can admit a patient covered by Medicare?
Answer: YES! On April 9, CMS temporarily suspended certain regulatory requirements through 1135 waivers so that home health care could maximize their frontline staff during the COVID-19 national health emergency, which included a key rule for occupational therapy. CMS has temporarily suspended the rule that would prevent OTs from opening Medicare home health cases, with a retroactive effective date of March 1, 2020, through the end of the emergency declaration. Occupational therapists may now perform initial and comprehensive assessments for all home health patients receiving therapy as part of the plan of care.
The existing regulations at § 484.55(a) and (b)(2) would continue to apply that OTs and other therapists would not be permitted to perform assessments in nursing only cases. We would continue to expect HHAs to match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible. Therapists must act within their state scope of practice laws when performing initial and comprehensive assessments, and access a registered nurse or other professional to complete sections of the assessment that are beyond their scope of practice.


Regulatory & Policy Digest


HOME HEALTH and HOSPICE: CMS Issues Final Rule to Advance Interoperability, NAHC Report, April 24, 2020 – On March 9, 2020, both the Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) issued for display on the ONC web site final rules that advance the goals of interoperability of electronic health care records (EHR). On April 22, 2020 these rules went on display at the federal register (FR) and will be published in the FR on May 1, 2020.
The rule requires new policies for CMS regulated payers, specifically, Medicare Advantage organizations, Medicaid Fee- for-Services (FFS), Medicaid managed care, Children Health Insurance Program (CHIP) FFS programs, CHIP managed care entities, and  Qualified Health Plans (QHP)on the Federally-facilitated Exchanges(FFE), with some exceptions for the QHPs.

HOME HEALTH and HOSPICE: CMS Waives New Tests for Home Health & Hospice, NAHC Report, April 24, 2020 –CMS announced new Clinical Laboratory Improvement Amendments of 1988 (CLIA) waived tests in the recently released Transmittal 10048/Change Request (CR) 11747. Home health and hospice agencies operating under a CLIA waiver are able to perform these new waived tests.

HOSPICE: Hospice Payment Rates for Routine Home Care (RHC) on and after January 1,

2016, Palmetto GBA, April 23, 2020 – On hospice adjustments, the high rate is continuing to populate on the claim for the RHC days when the low rate should have been applied. As a result of additional research, it has been determined that there is a continuing overpayment issue that occurs with hospice adjustments. The resolution to this issue, implemented on January 20, 2020, did not correct it. A resolution to this issue has been scheduled for the October 2020 Release. Providers are advised to hold adjustments to claims with routine home care days when the prior days used are greater than 60. Please share with appropriate staff.
HOSPICE: Feds Release $20 Billion in CARES Act Funds, Hospice Portion Unclear, Hospice News, April 24, 2020

HOSPICE and PALLIATIVE CARE: Hospice and Palliative Care Providers Adapt to New Infection Control Demands, Hospice News, April 22, 2020

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

HOME HEALTH and HOSPICE: Medicare FFS Claims: 2% Payment Adjustment Suspended (Sequestration), Palmetto GBA

Education & Events

News Clips & Links

HOSPICE: COVID-19’s Impact on Hospice Referral Relationships, Hospice News, April 24, 2020
HOSPICE: Hospices Tackle Telehealth Challenges During COVID-19, Hospice News, April 24, 2020
HOSPICE: Cybersecurity a New Priority for Hospice Providers, Hospice News, April 22, 2020
HOSPICE: Hospices Contend with Medication Shortages Amid Pandemic, Hospice News, April 27, 2020
HOSPICE: Hospices to Leverage Data Analytics in Value-Based Payment Models, Hospice News, April 27, 2020

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