Category Archives: Home health management

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.


As OIG looks at improper payments, agencies should look at coders

Here’s why  it’s important to know who is REALLY handling your coding and billing

It may be time to take a harder look at your agency’s coding and billing practices to determine whether you’re at unnecessary risk of being charged with fraud  — particularly in light of this summer’s announcement that the U.S. Health and Human Services Office of Inspector General (OIG) will launch a new probe to identify improper payment patterns.

The OIG will use data from the Centers for Medicare and Medicaid Services CERT Program (Comprehensive Error Rate Testing) to look for agencies with improper payments, honing in on any identifiable patterns to compile a list of common characteristics among agencies CMS believes were improperly paid.

Last year, CERT identified some $7 billion in improper payments among home health claims.

“This new initiative by the OIG sends a strong message to the home health industry,” said J’non Griffin, owner and president of Home Health Solutions LLC. “The period of hesitancy during the administration changeover earlier this year is ending, and we’re getting back to business as usual, with continuing scrutiny on home health for evidence of fraud or wrongdoing.”

How can agencies mitigate their risks for fraud or non-compliance?

Outsourcing services to a competent and professional firm is one of the best ways in which an agency can continue to focus on delivering quality health care instead of struggling to meet the compliance burden – but J’non cautions that outsourcing may have its own risks.

Agencies which rely on outsourcing for coding and billing should protect themselves by being especially  diligent not just in vetting the reputation and credentials of the firms contracted to provide services, but in ascertaining the credentials of the employees who actually perform the outsourced work for the company, J’non said.

Questions which agencies should be asking as they seek reputable outsourcing firms include:

How many of the reviewers are clinicians?

Are employees experienced in the home health and hospice fields? How many years of experience do they have?

Are they credentialed in home health and hospice specific coding?

Are the reviewers located in this country or abroad?

Are they HIPAA trained?

Are they familiar with the U.S. Health and Human Services Office of Inspector General focus on suspected fraud? Do they understand the importance of compliance to your agency’s success?

Are they knowledgeable about CMS requirements and otherwise well prepared to protect your agency?

“These are important questions for agencies to ask – more important in the long run than pricing,” J’non said. “Agencies can’t afford the cost of shoddy work quality in such heavily scrutinized circumstances.”

The HHS Who’s Coding You Challenge

Home Health Solutions LLC has announced an industry-wide “Who’s Coding You?” challenge in an effort to take the anonymity out of the outsourcing business and reassure home health agencies about the credentials and knowledgeability of our staff.

Over the next few months, we’ll be spotlighting the names, faces and credentials of all our team members to introduce to the world the people who make up our company.

“We’re proud of the HHS team and confident in the commitment to quality our team members show every day,” J’non said. “Instead of hiding our best and important assets behind the company name, we want to show them off, creating the opportunity for agencies to get to know each one of them, and learn firsthand how committed they are to doing the right thing for the agencies we serve.”

Other OIG concerns

Other areas of concern for agencies included on  the July work plan posted by the OIG include plans to evaluate Medicare Part A payments to home health agencies to determine whether claims billed to Medicare Part B for services and items were permissible and in accord with federal regulations. Certain supplies, items and services provided to inpatients are covered under Part A and should not be separately billable to Part B.

According to Section 1842 (b)(6)(F) of the Social Security Act, consolidated billing for all home health services is required while the beneficiary is under a home health plan of care authorized by a physician. The Act established a Medicare prospective payment system that pays home health agencies (HHA) for home services and covers all of their costs for furnishing services to Medicare beneficiaries. Pursuant to the home health consolidated billing requirements, the HHA that establishes a beneficiary’s home health plan of care has Medicare billing responsibility for services furnished to the beneficiary. Payment is made to the HHA whether or not the item or service was furnished by the HHA or by others by arrangement.

The OIG will review Medicare Part A payments to HHAs to determine whether claims billed to Medicare Part B for items and services were allowable and in accord with Federal regulations.

The OIG work plan also announced that it will review Medicare claims paid for telehealth services provided at distant sites that do not have corresponding claims from originating sites to determine whether those services met Medicare requirements.

Here is a link to review the OIG work plan.

10 Things Your Agency Can Do NOW to prepare for new CoPs

EDITOR’S NOTE: This article first appeared in the March 1 issue of The Absolute Agency, a free best practices resource emailed to agency administrators each month. To subscribe, click here.

It’s been almost 30 years since CMS changed the rules for home health agencies participating in Medicare, but the summer of 2017 will usher in both small and large changes in operational aspects of home health care.
Agencies must be prepared by July to meet most of the newly revised Conditions of Participation, although emergency preparedness plans won’t have to be in place until November.
If you’re feeling intimidated by scope of new changes on the horizon,  Home Health Solutions owner and president J’non Griffin has this advice about how to swallow an elephant:
One bite at a time.
Home Health Solutions will be focusing in greater detail on these and other aspects of the revised CoPs during the next few months, but there’s no need to wait to get your agency ready for the changes. Here’s our To-Do List of 10 simple tweaks, small changes and easy projects you can do right now to prepare for July and get ahead of the game.

1. Create An Organizational Chart.
If your agency doesn’t have one, start one.  Establish a clear chain of command.
Already have an organizational chart? Great! Make sure that it has a Clinical Manager who is responsible for making assignments, coordinating patient care and performing many of the functions currently falling under the duties of a Supervising Nurse.  Having a Clinical Manager is one of the new CoP requirements.
This doesn’t have to be one person. It’s OK to have more than one Clinical Manager on your chart.  Neither will your Clinical Manager have to be an R.N. Under new CoPs, the professional in this role may be nurse, therapist, social worker, even a doctor.
Your organizational chart will need to be in writing, along with all other agency policies.

2.  Create or Review Existing Job Descriptions.
You’ll need a job description in writing for each person who works at your agency – and the job description will need to include licensing requirements as applicable for specific positions. This will vary from state to state, so resist the urge to copy a great job description from an agency in another state.  You’ll have to make sure you do your homework so that your job descriptions are unique to your agency and match your state’s requirements.
Make certain, in the case of your Clinical Manager, that the job description highlights the primary responsibility as COORDINATION of services, patient care, etc.

3.  Check Your Watch. 
Now make it a habit. There’s no time like the present to start cultivating a new habit, and your entire staff is going to need to become much more time-conscious under new CoPs.  Clinicians will need to get into the habit of including the TIME in all visit notes.
There’s new wording in the CoPs, and it’s all about what time it is: time of arrival, time of departure, time that a service was provided,  and what time it was when someone on your staff spoke to a physician. It’s no longer enough to record the date on which an order was received; you’ll need to record the time, too.
Give your staff plenty of time to get into the habit; start requiring the documentation of time today.

4.  Start collecting phone numbers and contact info.
Under new patient rights established by the CoPs, you’ll be required to share with patients the phone numbers, addresses and contact information for a variety of state and federal agencies serving your area, including:
— Agency on Aging
— Center for Independent Living
— Protection and Advocacy Agency
— Aging and Disability Resource Center
— Quality Improvement Organization

5. Update Your Patient Info Packets
While you’re adding the list of numbers and contact info to the patient rights and information packets you provide to your patients at Start of Care, spend some time reviewing and evaluating exactly what you’re handing out and how well it is organized.
Is it easy to understand? Can you edit or rewrite any portion of it to make it simpler or any clearer? Does it spell out clearly how a patient, caregiver or representative is to report a problem or file a complaint – and to whom?
Under new CoPs, you’ll need to make sure to provide the patient with the name, phone number and contact information for both the agency administrator and clinical manager.
Make sure to include in writing your agency’s transfer and discharge policies. New CoPs will require you to provide this information to patients.
There are many other new patient rights requirements, too, but working now on these particular elements now can put your agency ahead of the curve.

 6.  Take steps to erase language barriers.
Make certain your agency can easily provide interpreters and copies of patients rights and information in the native language of the patient. Even if your agency does not currently serve patients who speak a language other than English, you must be prepared to overcome language barriers in the event that such a patient needs your care.
Start developing a plan now for securing interpreters as needed, and draft a written policy addressing how your agency will handle this situation should it occur.

7.  Medication Regimen Review.
Make sure you are conducting a review of all meds the patient is currently using and perform a reconciliation. Clinicians are already asked to do this as part of OASIS, but under new CoPs, your agency will be required to review all medications a patient is taking — including those prescribed by other care providers —  to identify, review and resolve any discrepancies.

8. Speed it up!
Work on getting faster in every aspect of your agency’s operation. Tighten your deadlines and stress to your staff the importance of streamlining and expediting paperwork.  Under new CoPs, you’ll need to have summaries prepared much faster, meet expedited turnaround times, be able to provide complete information to patients by the next home visit upon request, and follow through on discharged patients within a 5 business day window, providing a discharge summary to the agency, physician or other entity into whose care the patient is being transferred.

9.  Take a new look at how to safeguard private health information.
Under new CoPs, you’ll need a detailed written policy establishing procedures to be followed in the event of loss, theft or destruction in any manner of a computer on which private medical records are stored.  This is a good time to start detailing that policy.

10. Start working on your agency’s Emergency Preparedness Plan. 
Agencies have until November to get together the detailed Emergency Preparedness Plan required by new CoPs – but this is a complex undertaking with many components, and getting started today is the best course of action.
Start by calling your local Emergency Preparedness Agency today to set up a time to meet with a representative who can help you with one of the most intimidating pieces of this project for many agencies: the coordination of communitywide resources and other facilities.  FEMA already has access to much of the information you will need for your plan, including detailed studies and existing coordination plans which can be incorporated into the unique plan you will be required to craft for your agency.
As an example, you’ll need both a Hazardous Risk Assessment and a Communication Plan. Flood Risk Assessments from FEMA for your area may provide the specific information you will need to include in your own assessment. Your local agency may also help you develop a workable Communication Plan specifying how to get in touch with staff, patients, patient families and caregivers, as well as other facilities in the community in the event of a disaster which takes down phone and/or power lines, knocks out satellite communications and makes normal channels of communication impossible.

Cross these 10  items off your To-Do List and you’ll already be 10 sizeable bites into the elephant as the calendar turns toward July, ushering in the revised Conditions of Participation.
Bon appetit!

Three steps to take when your home health referrals drop


When a home health agency experiences a decrease in the flow of patient referrals, it’s easy to turn a critical eye toward the sales and marketing team. That’s exactly where the evaluation should start, but all too often, it’s also where the evaluation stops.
To experience true referral growth, agency management must shoulder some of the responsibility for the decline in admissions.
did-you-know-we-save-hundredsSales is a vital and important part of driving growth, but home health agencies which fail to deliver an in-house customer experience matching sales expectations are stacking the cards against success.
Here is where the tough love comes in: In many situations, we tell our sales team to sell a service that our employees are not inclined to provide. We assume our operations side is prepared to deliver what our sales side has promised, but without intentionality on our part to have the two sides work together, we won’t feel that synergy. An agency which does have that synergy in place almost never faces a referral decline.

Thousands of blogs and articles have been written about evaluating and motivating a sales team. Below I have outlined 3 key steps to evaluating the other parts of your agency to ensure that you are providing the experience that encourages referral sources to work with you.

Step 1: Evaluate your approachability

We all work with that one person who lacks a proverbial “filter.” Some folks can be incredible clinicians, but have communication skills that are lacking. It is really our responsibility if we let those individuals communicate with our clients and referral sources. One bad attitude on a bad day can lose a referral-providing physician or facility forever. With stakes that high, we cannot afford to risk our customer experience.
The resolution here is to evaluate and educate. When you find that a team member lacks the level of customer service you would expect, take the time to educate them or simply remove them from the phone queue.

Step 2: Consider your referral process

Some referral sources will seriously consider which agency provides the best service, the best care, and has the most trusted outcomes. However, many will simply look for the one that is easiest to work with.
When you get an order, do you call the referral source, ask for more info, ask them to fax a slightly modified version of the order, or request a new order to reflect your inability to admit the patient in 48 hours? We all have those days — and many times it is crucial to take these steps in order to secure accurate documentation needed for compliance.
Bear in mind, however, that another provider who is prepared to admit the patient without bothering the referral source for more of their time and effort may be perceived as more efficient.
Education is the key to resolving this conflict of interests. It’s not just your staff that needs the education here, it comes down to you having to educate your physicians and discharge planners on the process. Either way, keeping referral sources content is often directly related to how simple and streamlined it is to work with you in comparison to other providers.

Step 3: Cultivate a sales culture

If you cannot keep your patients and referral sources engaged and content, you are one good competitor away from losing your position in the market. Considering the steps outlined above, this may be the most important and the glue that keeps the other two steps together. Without your patients you have no business.
Taking the time to set solid expectations and guidelines foryour entire company – and focusing on providing an out-of-this-world customer experience – will have far reaching returns.

If you are seeing your referrals falling, consider treating the whole agency instead of just the symptoms. You will most likely see an increase in census and a prevailing culture of growth from a team that knows each person makes a difference.

 EDITOR’S NOTE: Jason Lewallen serves as Director of Sales and Marketing for Home Health Solutions. Jason is an accomplished speaker, blogger and author, with work published in Caring Magazine, The Home Health Technology Report, HME News, and Curaport. This article first appeared in SOLUTIONS, the monthly e-newsletter produced by HHS.