Here’s what you need to know about our helpful EP Assembly Kit

THREE MONTHS FROM TODAY.  When surveyors show up at your home health agency in just three months from today, they’ll expect to review your Emergency Preparedness program.

Yes, the start date for new CoPs has been delayed until January 2018 — but don’t get confused. Your agency is still required to have its Emergency Preparedness Plan in place by this November.

Home Health Solutions Owner and President J’non Griffin has been traveling across the country to present workshops to help agencies meet the new Emergency Preparedness requirements in time for November surveys.

Her expertise is also condensed into an easy-to-follow 12-Step EP Assembly Kit available for order now in the Home Health Solutions online store.  The Kit takes the cumbersome process of developing Emergency Preparedness policies and procedures and staging a community-wide disaster drill, and makes it simple to execute.

Wondering how the kit works? Check out these EP Assembly Kit FAQs:


1. What format is the Kit presented in?
The Kit comes to you in DIGITAL format so it is available immediately. You can get started on your Plan instantly!

2. What exactly comes in the Kit?

A VIDEO in which Home Health Solutions Owner J’non Griffin explains the Emergency Preparedness Program which new Conditions of Participation will require agencies to have in place by November of 2017.

A 12-STEP GUIDE which breaks down the cumbersome process of developing your agency’s program into 12 easy-to-follow steps. We explain each step and provide the materials you will need to implement it. One of the steps, for example, explains how to set up a community meeting with Coalition Members to plan your community drill. We include a copy of the invitation letter for you to send, a list of other facilities and/or community groups to send it to, and an agenda to follow at the meeting.

A SAMPLE PLAN to show you what your completed Plan should look like.

— A section we call THE TOOL PACKET.  It is filled with all the forms you’ll need to capture the information to fulfill the requirements of the CoPs for creating an Emergency Plan. There’s a sample Phone Tree and Crisis Communications Form for creating your agency’s Disaster Communications Plan, a sample Hazardous Risk Vulnerabilities Assessment, etc. This section includes more than 30 forms and tools.

An EP Survey Readiness Guide. We’ve used Interpretive Guidelines to create an at-a-glance look at exactly what Surveyors will be looking for when reviewing new agency Emergency Preparedness Plans.

3. Does the Kit explain how to stage a community-wide disaster drill? Yes. Our 12-Step Guide explains exactly how to go about planning this event, from who to invite to participate with you to a sample letter to send out to invite participants to a planning meeting. We include an agenda for that meeting and samples of items you will need to discuss and lists you will need to compile at the meeting. We can’t have the meeting or stage the actual drill for you, but we make it as easy as possible!

4. What about the Training and Testing portion of the Emergency Plan requirements? Our Tool Kit includes training materials on various natural or man-made disasters which you will be able to copy and provide to your patients and staff to fulfill CoPs disaster training requirements. Just be sure to document that you have provided these materials and when the training occurred.
We also include some sample evaluation forms to use to review the communitywide drill afterward to help  in conducting an annual evaluation of your Emergency Plan.

5. What is the “All Hazards” Risks and Vulnerabilities Assessment our agency is required to have, and is it included in the Kit? Our kit explains what this assessment is, and we provide a sample for you to follow. We also explain how to create your own Risk Assessment specific to your agency and community.

6. How long is the 12-Step Guide? How much reading will be required? We know you are busy so we have kept the entire Guide – all 12 steps and all the forms and tools included – right at 100 pages. The EP Survey Readiness Guide is a separate document, provided in spreadsheet format.

7. Our agency will need to have a written Policy outlining our Emergency Plan. Does the Kit address this need? Yes. A sample written Policy is included in the Kit. We recommend that you use it as the basis for your agency’s policy. It will meet federal requirements in its current form, and you can easily add any state-specific requirements to it. Some states, including Florida, will have a few extra Emergency Preparedness requirements that CMS does not require. Our 12-Step Guide directs you to work with your local Emergency Management Agency on the development of your plan, and your local office will be able to provide any local and/or state requirements which must be met in addition to what CMS requires.

8. How long will it take to get together our agency’s Emergency Program using this Kit? That depends on how many components of the program your agency already has in place and how quickly you are able to set up a meeting with your Coalition Partners and stage a community-wide disaster drill. In most cases, this project will take weeks of planning and collecting information, so we recommend that you get in started well in advance of the November deadline.

9. Our agency already has an Emergency Operations Plan in place, so we do not want to order the Kit. But we would like to know whether our existing plan meets new CoPs. We have the solution: the piece of our kit known as the EP Survey Readiness Guide may be purchased separately. Based on Interpretive Guidelines, this helpful guide is available in an easy-to-read, spreadsheet format and will review all aspects of the Emergency Program requirement along with bulleted points showing exactly what Surveyors will be looking for. Check our online store to order the Survey Readiness Guide.

Remember, Home Health Solutions also provides customized education and training to home health agencies. Owner and President J’non Griffin will work with your agency to make certain you comply with the new Emergency Preparedness and Infection Control program requirements as well as any other aspects of the new CoPs.

How the new HHGM would affect home health agencies

This article first appeared in The Monday Fix, our free weekly e-newsletter. To subscribe, click here

proposed rule updating the home health prospective payment system would lower payment rates to home health agencies next year and completely overhaul the way Medicare pays home health agencies the following year.

CMS estimates that the cost to agencies for implementing the rule published to the Federal Registry on Aug. 4 would be about $80 million in 2018. 

But the rule has garnered more attention for the changes it would bring about in payment structure for episodes of care provided by home health agencies, shortening the national standardized 60-day episode payment to just 30 days beginning Jan. 1, 2019, and replacing the current therapy-driven payment system with a model largely based on six clinical groupings. 

CMS calls the revised payment model a “more clinically intuitive system” and said it will align with the way clinicians already categorize their patients to deliver care. 

The new model is predicated on the use of principal diagnoses as the core of the system to more clearly identify the types of patients treated in home health, and the focus of their care,” said J’non Griffin, owner and president of Home Health Solutions LLC.

   Each 30-day payment period would be assigned to a clinical group according to the primary reason the patient was receiving home health. CMS would use the principal diagnosis code reported on the home health claims to assign the grouping to one of these 6 classifications:

  • Musculoskeletal rehabilitation
  • Neurological or stroke rehabilitation
  • Wound care
  • Medication Management Teaching and Assessment
  • Behavioral health care (including psychiatric and substance abuse conditions)
  • Complex nursing care (IV therapy, ventilator, ostomies, parenteral or enteral nutrition, etc.)

Questionable encounters
Under the new payment model, 30-day payment episodes which could not be grouped by primary diagnoses due to coding issues would be considered “questionable encounters” and returned to the provider for more accurate or definitive coding. 

CMS has announced that it will post on its web site a list of codes which would be considered “a questionable encounter.”

“We believe this will help to minimize any returned claims for more definitive coding,” CMS states in its proposal. “Each code should be reported to the level of certainty and specificity known for the home health admission. Under our proposal, secondary diagnosis codes would not be used to assign the clinical group, as the intent of the HHGM is to increase clarity by classifying the 30-day period based on the primary reason for home health services.”
Other factors will be considered 
Although the principal diagnosis code would be the basis for the home health episode, secondary diagnosis codes would be used to case-mix adjust the period further through additional elements of the model, such as co-morbidity adjustment.
“The relationship between function and cognitive status and episode cost will also take on increased significance under the new model,” J’non said. “Each of the primary diagnosis groupings will be ranked either high or low in terms of functional/cognitive level. Four of the 6 clinical groupings will have an additional medium category.”

In all, the new 30-day home health category will be classified according to:
– TIMING — Early or late episode
– REFERRAL SOURCE – Community or institutional
– CLINICAL GROUP – One of the 6 primary diagnosis-based groupings listed above
– COMORBIDITY ADJUSTMENT – Determined by secondary diagnoses  

Under the new model, diagnosis codes would support medical necessity for services furnished, and provide information for establishing the home health Plan of Care, according to CMS.


“Ultimately, developing clinically similar groups based on the reported principal diagnosis as part of the larger structure of the model would allow for more meaningful analysis of home health resource use, ensure that patients are receiving care commiserate with their level of need, and more accurately align payment with cost,” CMS said.


Hospice rule approves 1% payment increase for 2018

As home health news spotlights a proposal by the Centers for Medicare and Medicaid Services to overhaul the Medicare payment system beginning in 2019, hospice agencies have been quietly evaluating some changes CMS has in store for them in the next fiscal year.

CMS has authorized a 1 percent increase for hospice payments beginning Oct. 1, 2017, in a Final Rule for FY 2018 which also updates the hospice wage index and places a cap amount for the fiscal year.

Other noteworthy content in the Final Rule is a decision not to make a previously-discussed regulatory change regarding requirements for clinical information to certify life expectancy, and updated information about a comprehensive new patient assessment tool which is now under development. The tool will eventually be used to replace the existing Hospice Item Set known as HIS.

CMS initiated a 60-day comment period last May on the measures addressed in its FY 2018 Final Rule, and both the comments received and its responses appear in the Final Rule published to the Federal Registry Aug. 4.  The Final Rule may be viewed by clicking here.

“Many of the commenters expressed concerns that the 1 percent increase was not substantial enough, but CMS explained that the 1 percent payment update for FY 2018 is mandated by section 411(d) of MACRA, the Medicare Access and CHIP Reauthorization Act of 2015, ” said J’non Griffin, President and Owner of Home Health Solutions LLC.

“In addition, CMS clarified some aspects of the clinical information now required for certification of life expectancy and decided against making any change at this time in regulations regarding accurate sources of the required information, ” J’non said.

She offered a few other highlights from the Final Rule:

Wage Index Update and Payment Rate
In addition to approving a market basket percentage increase of 1 percent for hospice payments in FY 2018, the Final Rule updates the hospice wage index, which is used to adjust payment rates under the Medicare program to reflect local differences in area wage levels, based on the location where services are furnished. The wage index applicable for FY 2018 is available on the CMS website at:

Cap amount established
The hospice cap amount for the 2018 cap year will be $28,689.04, which is equal to the 2017 cap amount ($28,404.99) updated by the FY 2018 hospice payment update percentage of 1 percent.

Certification of life expectancy
CMS decided not to make a change at this time in the regulations at §418.25, clarifying that the documentation used the initial certification of a medical prognosis of a life expectancy of 6 months or less must come from medical records provided by the referring physician or acute/post-acute care facility.

CMS also confirmed that “…this clinical information can be obtained orally from the referring entity and documented in the patient’s chart within the 2 day time-frame needed for certification” and clarified that the hospice medical director or physician designee would not be required to perform a face-to-face visit before the third benefit period recertification, as currently required by the regulations at §418.22(a)(4).

“In announcing the decision not to make the regulatory change at this time, CMS stated that it plans to work with Medicare Administrative Contractors (MACs) to confirm whether specific information about appropriate sources for required clinical information should be included in additional documentation requests,” J’non said.

HQRP updates
 Quality Reporting updates in the FY 2018 Final Rule include some changes in compliance criteria.

Hospices will be allowed 60 extra days to request an exemption or an extension when submitting quality data for HQRP.  Currently, hospices have 30 days in which to submit requests for extensions or exemptions. Under the change, a hospice which suffered damage due to a hurricane on Jan. 1, for example, would have until March 31 to submit a request form to CMS.

The 90-day period would apply to requests for exemption or extensions in submitting multiple types of data, including HIS data and the requirement to collect Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Hospice Survey data on a monthly basis.

CMS also proposed a scoring change for CAHPS® Hospice Survey measures and proposed some new measures. Details on the specifications of these measures, including details regarding the proposed scoring methodology and mode and case-mix adjustment, may be viewed on the CAHPS® Hospice Survey webpage at

Hospice Item Set updates
Although it did not implement a new patient assessment tool in the FY 2018 Final Rule, CMS said it wants to bring the current Hospice Item Set (HIS) data collection instrument in line with other post-acute care settings, and is working with a contractor to develop a comprehensive patient assessment instrument which would replace the current HIS.

The new data collection tool is preliminarily called the Hospice Evaluation & Assessment Reporting Tool, or HEART.

“Basically, the new tool would function as an expanded HIS, with additional clinical items that could also be used for payment refinement purposes or to develop new quality measures,” J’non said.

“HEART would not replace any of the existing requirements set forth in the Medicare Hospice CoPs (such as the initial and comprehensive assessment), the CAHPS® Hospice Survey or the regular submission of claims data, but would instead be designed to complement data collected as part of high-quality clinical care,” J’non said.

Patient assessment data would be collected upon a patient’s admission to and discharge from any Medicare-certified hospice provider, she added.