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Tip: CMS offers exemptions to the Community-Wide Disaster Drill

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Tip #2: Full-scale exercise exemption
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Of all the new Emergency Preparedness requirements expects home health agencies to meet by November, the community-wide disaster drill (full-scale exercise) is the most intimidating and labor-intensive for many agencies.

The community-wide drill is one of two exercises CMS expects home health agencies to stage each year. The second exercise may be a tabletop version, in which the emergency situation is plotted out via paper-only, with participants seated around a discussion table and “talking out” the procedures.

But the community-wide drill is a full-scale exercise requiring agencies to work with other agencies in their communities such as first responders, emergency management officials, hospitals, clinics, assisted living facilities and others to stage a mock crisis, and conduct a detailed evaluation afterward of how well things went, identifying areas for improvement.

The drill is a major undertaking, requiring much planning and coordination.
Did you know, however, that your agency may be exempt from the community-wide drill until next year if you experienced a crisis which required activation of your Emergency Plan? Many agencies in Florida, Texas, Louisiana, South Carolina and Georgia as well as agencies in the Virgin Islands and Puerto Rico were required to activate emergency procedures during this fall’s spate of damaging hurricanes.
Wildfires in California are currently threatening areas served by home health agencies.

If your agency is located in one of these affected areas – or if you are located in a different area of the country where you experienced a crisis such as tornadic activity, flooding, a blizzard or any other emergency which required your agency to activate emergency procedures – you appear to be exempt from staging a community-wide disaster drill before Nov. 16.

Documentation of the activation of your emergency procedures will be required, as well as a thorough evaluation afterward.

Note that you will still need to have conducted a tabletop exercise by the deadline in order to be compliant.

Here is what CMS says on its web site about this exemption:

NOTICE ON TRAINING & EXERCISES: If a facility activates their emergency plan due to a disaster, the facility is exempt from one full-scale/individual based exercise for that year. However, the secondary requirement for a table-top exercise or exercise of choice still applies. Facilities must demonstrate completion of two exercises per annual year.

You can read for yourself what CMS says about the full-scale exercise at:

Infection Control: A 6-Point Outline for Your Agency’s Staff Training

An effective staff training program is one important part of the Infection Control Program mandated for home health agencies under new Conditions of Participation in Medicare.

“Many accreditation programs already require home health agencies to have in place Infection Control Programs, but under new CoPs all agencies participating in Medicare will need to have specific programs focusing on prevention, control and ongoing education for both patients and staff, ” says J’non Griffin, owner of Home Health Solutions, LLC.

J’non is conducting CoPs training workshops across the country to help agencies prepare to meet the new regulations, including three full-day workshops this week in Tampa, Orlando and Ft. Lauderdale.

Here’s her 6-point outline for setting up a CoPs-compliant staff training program at your agency.

    While there are some standard risks that every home health agency must address when developing an effective infection prevention and control program – influenza and tuberculosis, for example — it’s important for your agency to exercise some diligence in determining risks which may be specific to your geographical area, or to your patient population.
    Some areas of the country experience a higher incidence of HIV, for example. Elderly populations may have less resistance to certain bacterial infections.
    State health departments should have statistics for your area, many times online. But you can also start with a call to your local public health department to glean statistics that can help you identify infection risks specific to your agency.
    Document the results of your risk identification efforts, and provide specific training to your staff in each of the areas identified, as well as measures to control the spread of communicable and infectious diseases commonly occurring.
    There’s a lot of ground to cover with each of your new hires, but don’t neglect to include infection control measures in your orientation program.  Implement a “See No Clients Until” rule at your agency precluding any staff member from making a home visit until infection prevention and control training has been received.
    Because many of the elements of an effective infection control program seem simple and obvious — including basic hand hygiene, protective nursing bag techniques, and exercising care with IV, catheter and gastric tube changes — it can be tempting for busy home health agencies to discount the importance of training.
    Be careful not to shortchange your training sessions.
    Devote at least a full hour to each session, and make certain each of your employees receives a full hour of training no less frequently than once a year.
    Your agency should be able to show Surveyors at a glance who in your agency has received training in infection prevention and control, when the training occurred, which topics were covered, and who presented the training. You should also be able to easily identify staff members due for another round of training. Infection control and prevention measures should be addressed in training sessions that occur at least every 12 months.
    Make certain that your records include forms signed by all staff members attesting to attendance in training sessions – and that the staff member understood the material covered in the session.

    Self-evaluation is a consistent theme found throughout new Conditions of Participation. CMS wants to see evidence that your agency is monitoring its own efforts and addressing any shortcomings.  Make certain that you apply this self-testing approach to staff training as well as all other aspects of your operation.
    Take a look at your training program at least once every 12 months to see how well it’s working.  Some questions to ask as part of your evaluation include:
  • Are all your employees up to date on their training?
  • Have you have an outbreak of an infectious disease among staff members since your last evaluation – and if so, how well were you able to control it? Do staff members need additional training to address deficiencies?
  • Are you checking frequently with state or local public health authorities for current information and updating your agency’s risk assessment accordingly?  Offer staff training in any new areas of risk identified.

We can help!

Home Health Solutions can help your agency with its implementation of an effective Infection Control program in several ways.
One of the most important elements of creating your program is the development of policies and procedures outlining your program’s scope and how it will be implemented. We’ve covered that in our Policies and Procedures Manual, one of two CoPs-compliant manuals ready for your agency to purchase and customize.
You can also read more about the development of your agency’s Infection Control program in Volume III of our CoPs COMPANION series of four guidebooks designed to walk you through the transition to new CoPs.
Check out both these products in our online store by clicking here.

No Emergency Plan yet? Programs must be in place by November 15, 2017

Last month’s reprieve from continuing pre-claim review demonstrations by the Center for Medicare and Medicaid Services and the announcement that CMS is considering a delay in the start date for new Conditions of Participation has created a sense of cautious relief in the home health field.

Many home health professionals are wondering if the reprieves and delays reflect a trend away from increasingly stringent compliance demands on home health agencies in recent years.

But gambling on the advent of a more relaxed regulatory climate could have negative consequences for agencies – including CMS citations for non-compliance beginning in November for agencies failing to meet new Emergency Preparedness Program requirements, warned J’non Griffin, president and owner of Home Health Solutions LLC.

“It’s really important not to lose our sense of urgency in home health,” J’non said. “Emergency Preparedness Programs should be a priority for agencies right now. The programs take a while to put into place, and CMS has said that agencies will be expected to meet EP requirements by Nov. 15, 2017, or be cited for non-compliance.”
A proposal CMS is now considering to push back the start date for revised Conditions of Participation is not expected to impact the Nov. 15 effective date for Emergency Preparedness Programs.

“This means that regardless of whether CoPs are implemented on July 13, 2017, or pushed back six months until January, 2018, home health agencies will need to have in place their Emergency Preparedness Programs by this November,” J’non said.

Community wide disaster drills

To avoid non-compliance, beginning Nov. 15, agencies will need to have already conducted the community-wide disaster drills which are part of the CMS-mandated Emergency Preparedness Programs.

This requirement has been one of the most intimidating to many agencies, according to J’non, because it requires them to pool efforts with local and state emergency agencies and health care coalitions to conduct full-scale community exercises.

Under the Final Rule mandating home health Emergency Preparedness Programs, two of these drills are required annually for agencies to test their emergency operations, although one of the drills may be a tabletop exercise.  Agencies experiencing real emergencies may be excused from one of the required yearly drills.

Some agencies have not yet begun efforts to coordinate the disaster drills because they are hoping additional guidance will be provided when interpretive guidelines for the new CoPs are issued.

“Agencies really shouldn’t wait for interpretive guidelines to be issued. CMS has specifically addressed this issue, stating that agencies must perform their community wide disaster drills by Nov. 15,” J’non said.

On its web site, CMS states:

“We realize that some providers and suppliers are waiting for the release of the interpretive guidance to begin planning these exercises, but that is not necessary nor is it advised. Providers and suppliers that are found to have not completed these exercises, or any other requirements of the Final Rule upon their survey, will be cited for non-compliance.”

Agencies unable to comply

Agencies unable to conduct a community-based exercise by the deadline may be able to document why and avoid citation for non-compliance as long as reasons are valid, J’non said.

In rural areas, for example, agencies may not have access to the same resources as agencies in more populated areas. In a community in which an annual disaster drill is already scheduled to take place after the Nov. 15 deadline, it may make more sense for an agency to wait and join existing community efforts.

Agencies who find themselves in these or other situations which hinder efforts to comply with the disaster drill mandate must thoroughly document efforts to coordinate a community wide drill, explaining why it was not possible within the time frame, according to J’non. They will still need to conduct and document a facility-based disaster drill, she said.

On its web site, CMS identifies these documentation requirements:

“The documentation should include what emergency agencies and or health care coalitions the provider or supplier contacted to partner in a full-scale community exercise and the specific reason(s) why a full-scale exercise was not possible.”

Where to find help

Home Health Solutions offers an Assembly Kit that breaks down the development of an Emergency Preparedness Program into 12 easy-to-follow steps, offers a Sample Plan to follow, and provides more than 30 assessment tools and forms which will be needed to capture the right information for creating a fully compliant Emergency Preparedness Program.

It’s designed to simplify the process for busy agency executives with a format anyone can easily follow to meet CMS requirements.

The Assembly Kit can be purchased at:

The CMS web site offers resources such as checklists, links to emergency preparedness agencies, planning templates and many other aids to assist agencies in developing Emergency Preparedness Programs.  The website also provides a State-by-State listing of Health Care Coalitions. The information can be found at:

What PCR reprieves, CoPs delay could mean

Future-gazing: A delay or not?
Either way,  there’s work to do!

It seemed almost too good to be true, like some April Fool’s Day prank offering false hope to home health agencies braced for a new onslaught of federal regulations.

Just one day before home health agencies in Florida expected to join Illinois agencies in a long-fought Pre-Claim Review (PCR) demonstration by the Centers for Medicaid and Medicare Services, two announcements by CMS changed the game. At least for now.

 After months of deadlock, a temporary reprieve from massive new regulatory changes – not just in Florida but nationwide – suddenly shifted from highly unlikely to plausible.

 CMS announced Friday that it would grant Florida a second reprieve from the PCR demonstration scheduled to begin April 1, suspend for at least 30 days the PCR program in Illinois which has been underway since August, and possibly give home health agencies an additional six months to prepare for new Conditions of Participation in the Medicare program.

   “These two developments made for an interesting Friday in home health,” said J’non Griffin, owner and president of Home Health Solutions LLC. “The PCR delay in Florida really was an 11th hour save. The clock was ticking, and agency personnel were attending last-minute PCR training workshops every day last week in cities all across Florida to get the information and training they needed to be ready for the PCR launch.”

 But brand new CMS administrator Seema Verma, who was just confirmed to her position at the Department of Health and Human Services on March 13, was also seeking information last week. She asked to meet directly with home health care providers and advocates from both Florida and Illinois, where the nation’s first PCR demonstration began last summer. The new CMS administrator said she wanted to hear their concerns about the impact of increasing regulatory demands on home health.

   Following that meeting, CMS on Friday announced plans for a 60-day public comment period to seek information that will be evaluated in determining whether to delay the implementation of new CoPs, standards which are widely expected to be difficult, time-consuming and costly for agencies to put into place. Under the current timeframe, agencies are required to meet new CoPs by July 13. The six-month delay, if approved, will give agencies until January, 2018, to make the necessary changes.

Soon after that announcement, word came from CMS that the PCR demonstration in Florida would no longer begin on April 1 as scheduled — and that the ongoing PCR demonstration in Illinois would be suspended for at least 30 days. CMS offered no further timetable for PCRs to resume, but promised a 30-day notice will be provided before that happens.

Relief, hope — and politics

Home health professionals across the country greeted Friday’s news with a mixture of relief and cautious hope for a changing climate in Washington D.C. regarding federal regulations on home care.

New Health and Human Services Secretary Tom Price has been described as knowledgeable about and supportive of many home health issues by William Dombi, Vice President of Law for the National Association of Home Care. At the 2017 Illinois Home Care and Hospice Conference last month, Dombi painted Price as a potential ally for home health, telling attendees that Price was considering supporting a CoPs delay.

But less than 100 days into a new administration, the Department of Health and Human Services headed by Price is still coming together, with many of its senior positions still unfilled.
And, as battles continue between lawmakers over the government’s specific role in health care, many of our nation’s health care policies have yet to be determined, much less put into place.

“It’s definitely a good sign for top officials in D.C. to actively seek input from home health and listen to our concerns, but there are still a great many unknowns right now,” J’non said. “No one really knows exactly how all this is going to play out.”

The future of PCRs and CoPs

What will the delays in Florida and Illinois mean for PCR demonstrations?

Industry experts believe it is likely that CMS will make changes to the PCR model before continuing with the demonstration first launched in Illinois last August. The demonstration in that state proved to be so chaotic, confusing and largely unsuccessful in its initial months that CMS was forced to pull the plug on expansions planned for Florida the following October and into Texas, Michigan and Massachusetts by the beginning of the year.

With the issues that plagued Illinois corrected, what might the revised demonstration look like?

“It really isn’t possible to say for certain at this point,” J’non said. “It seems more important to note that the PCR demonstration will go forward. This is a delay, and not a repeal. Agencies in all states still need to add PCR readiness to their ongoing training efforts.”

Under the current model, agencies in states where the PCR demonstration operates have the choice to participate or not. However, those who do not submit the proper paperwork for review prior to filing actual claims will automatically lose 25 percent of any Medicare reimbursement on claims not previewed.There has been no word at this time that the 25 percent reduction for non-participation will change.

While dramatic, last-minute PCR suspensions in Florida and Illinois grabbed most of the attention on Friday, the CMS announcement regarding a possible delay in the implementation of new Conditions of Participation could have a more immediate impact on most of the nation’s 30,000 home health providers.

The implementation of most new CoPs would be delayed until January 13, 2018, under the proposed rule.

Agencies would have extra time to meet some of the Quality Assurance and Performance Improvement (QAPI) standards required. Phase-in requirements would give agencies until July 13, 2018, to implement performance improvement projects, allowing six months after the January 2018 start date to collect the data they will be required to use in their data-driven performance improvement projects beginning in July 2018.

Administrators would be affected 
   Additionally, the proposed rule would grandfather all administrators employed by agencies prior to January 2018, so that they do not have to meet the new personnel requirements identified in the revised CoPs. 

  Of particular interest to agency administrators is what new personnel requirements will mean for future employment, and their ability to move from a grandfathered position at their current agency to an administrator position at a different agency.

Under the new CoPs, administrators who do not meet the requirements would lose their grandfathered exemption when they leave one agency to take a position at another agency, J’non said.
The clock is ticking

One of the primary arguments for delay of a start date for new CoPs has been concern about the lack of interpretive guidelines, which Surveyors will use to evaluate whether agencies have met the standards.

Agencies have expressed concerns they are not certain exactly what Surveyors will be looking for, particularly in the areas of data-driven performance improvement projects.
CMS agreed, in its announcement on Friday, that there is merit to that argument, and that is one of the reasons the delay is being considered.

“With so many other major clinical and operational changes to implement in such a short period of time before July 13, which is the start date effective under current law, there has been growing concern in the industry about the lack of time in which to put all of it into place,” J’non said.

   New Conditions of Participation were approved in January, giving agencies only six months to make the required changes. It was the first time in almost three decades that CMS addressed the standards set out for home health agencies under CoPs.

“With such a limited amount of time, agencies really need to be making the necessary changes now, without waiting on interpretive guidelines,” J’non said. “Guidelines are more for the benefit of Surveyors. Agencies must meet the standards as they are set out in the CoPs.

“It’s important to remember that the delay is only under consideration at this point, and the July 13 start date could remain in effect,” she said. Many agencies will not have the resources to make necessary changes on their own, especially under the current time frame, and will need to outsource much or all of the work, J’non said.

Even if the delay is approved, and extra time is granted, many of the new requirements will be so labor-intensive that agencies will still need to rely on outsourcing, she said.

Delays aren’t repeals

  J’non offered this advice to agencies wondering what these delays may mean and how they will affect preparation timelines:
“It’s important to note that, as with PCRs, a possible delay is not the same thing as a repeal,” J’non cautioned. “Agencies need to proceed as if the July 13 start date will remain in effect. If they wait, and the start date is not delayed at the close of the 60-day comment period, it will be too close to July to be able to implement the required changes by the deadline.”

EDITOR’S NOTE: This article first appeared in The Absolute Agency, a free monthly e-newsletter published by Home Health Solutions as a best-practices guide for agency administrators.
To subscribe, click here.

What are your agency’s 2016 goals?

January is the month traditionally littered with good goals gone bad.
You know the drill. We resolve to eat less and exercise more, avoid sugary desserts, get to bed earlier, spend more time researching or completing that next certification and less time on social media. And we do exactly that, for a few days.
Then somebody brings a big box of doughnuts to work and POOF. Just like that, our ambitions for 2016 are nothing more than sweet, sticky memories we’re licking from our fingers.
Business goals, of course, are a little different.
“We can’t afford to treat our business goals for 2016 as cavalierly as we sometimes treat our waistline goals,” Home Health Care Solutions LLC Owner J’non Griffin says. “It’s more important than ever before for those of us in the field of home health care to set and follow strategic goals designed to ensure quality patient care and bottom line performance.”
One of the crucial components in goal-setting for 2016, she says, should be developing long-term solutions rather than focusing on short-term fixes.
“Is your goal just to make money today?,” J’non asks. “Or is it to position your agency or organization for the future by putting into place the quality initiatives necessary to continue moving forward in a fluid and challenging home health care market?”
J’non will join a panel of industry leading experts at the HCAF Winter Gathering in Ft. Lauderdale next week to address many of the most critical issues facing home health professionals, guiding them in establishing quality initiatives.
The event runs from noon Monday, Jan. 11, until noon Wednesday, Jan. 13, and is being billed as a”crash course” in must-know info for more effective management strategy in 2016. J’non’s presentation will be: “Monitoring Quality Outcomes for the Future.”
Continue reading What are your agency’s 2016 goals?

Hunger Games strategy a win for home health care

Did you really just see Katniss Eberdeen in a Dodge truck commercial?

You may think you’re hallucinating from staring too long at the detailed new G Codes for home health and hospice agencies, the ones taking effect Jan. 1 as part of the latest change request from The Centers for Medicare & Medicaid Services.

But you’re not confused, at least not about Katniss and Dodge. (It would be highly unusual if you weren’t at least a little confused about the G codes.)

A “Hunger Games” lookalike is splashed all over television, radio, digital and social media advertisements this week in an unlikely marketing alliance with Fiat Dodge Chrysler Automobiles.

It’s part of a huge, cross-industry promotion for the release of “Mockingjay – Part 2,” opening in movie theaters this Friday, Nov. 20. Fiat Dodge Chrysler is taking full advantage of the surrounding hype to join forces in an expensive advertising campaign.

What can Katniss joining forces with Dodge teach the home health care industry?

The creative alliance between auto manufacturer and moviemaker is representative of a strong new partnership trend across many sectors of today’s marketplace, in team efforts designed to make sure the odds of success are a bit more favorable for all.

It’s a trend home health care can’t afford to overlook, because there can be real, bottom-line value in this type of strategic alliance.

In fact, strategic partnerships may well be the best route to profitability as home health evolves, particularly for smaller agencies feeling overwhelmed by the need to stay abreast of regulatory change, control risk and maintain solvency, all without sacrificing focus on quality patient care and outcomes. From community resource sharing to outsourcing traditional staff responsibilities such as coding and chart review, teamwork can play an integral role in helping home health and hospice agencies overcome today’s complex challenges.

John Hammergren, chairman and CEO of McKesson, the largest health-care services firm in the U.S., is among the health industry voices endorsing creative solutions, including strategic partnerships, in today’s fluid health services market.

“Given the unprecedented level of change gripping the health care industry, large and small health care organizations will need to depend on innovative, creative thinking and sometimes each other to successfully navigate the evolving marketplace,” Hammergren wrote in a recent article for the Harvard Business Review.

Health care strategist and author Stephen Tweed, CEO of Leading Home Care, agrees. Last spring, Tweed identified “Community Partnerships” as one of the Top 10 Trends in Home Health Care in America for 2015, on his Home Health Care Today blog, saying many home care agencies are partnering with providers and non-provider organizations to greatly improve health outcomes.

Communities may offer an abundance of helpful resources, from disease-specific program development assistance available through local branches of large nationwide advocacy groups such as The National Cancer Society or The American Heart Association to support groups for caregivers. Even rural agencies may be able to make use of resources available through the largest advocacy groups.

Compliance is one of the areas most conducive to partnerships adding bottom-line value to home health agencies. 

Continue reading Hunger Games strategy a win for home health care

How a Home Health Agency Improved Quality of Care with New Software


imgresWith rising financial costs and two software systems that did not integrate with one another, Advanced RehabTrust faced a slew of problems that lowered agency productivity and prevented them from providing the highest level patient care. recently published a case study that profiles how the deployment of new software helped this home healthcare agency improve operations. Advanced RehabTrust was able to realize the following after implementing the Kinnser home health software solutions:

With rising financial costs and two software systems that did not integrate with one another, Advanced RehabTrust faced a slew of problems that lowered agency productivity and prevented them from providing the highest level patient care. recently published a case study that profiles how the deployment of new software helped this home healthcare agency improve operations. Advanced RehabTrust was able to realize the following after implementing the Kinnser home health software solutions:

1. Improved Processing and Billing –
Before switching software, patient processing took from 2 – 3 weeks. Now, the process can be started within the first 24 hours of patient contact, and completed in less than a week.
Billing also saw significant advances. The two years prior to the software implementation, over $94,000 dollars were lost because of errors. Since, there have been zero dollars lost due to billing errors.

2. Better Patient and Agency Communications –
Even with 50 percent overall patient growth, Advanced RehabTrust was able to lower the time spent on communications because of the system’s scheduling functionality. The application organized the frequency of patient visits and provided reminders for the staff on important patient needs.

3. Faster Payroll Processing –
With new Web-based bookkeeping, payroll processing time was reduced from four days to four hours, and saved $1,000 a month because of the eliminated paper costs.

Advanced RehabTrust has seen several significant improvements since deploying its new system. They lowered their overall costs and most importantly, they improved home health care for their patients. Do you have similar instances of success with home health software? Please share your comments below.