Palmetto GBA expands Probe & Educate initiative

Home health agencies in the 16 states served by Palmetto GBA Medicare Administrative Contractor could see a significant increase in the amount of records reviewed as part of an expanded Probe & Educate initiative.

Some agencies could be required to provide as many as 20-40 records on average instead of the five records requested for previous Probe & Educate reviews, according to Bobby Lolley, Executive Director of the Home Care Association of Florida.

“This review will be extensive, with 20-40 records on average being requested, not just another five records like in previous rounds,” Lolley said in an email to HCAF forum members this week.

Agencies subject to the significantly increased record requests are those which received denials of two or more records reviewed in an earlier round of the Probe & Educate initiative.  Some of those agencies did not receive specific instruction they were expecting from the MAC as part of the process because the Probe & Educate initiative was suspended earlier this year.

Lolley said all agencies in Round 2 can be subject to further review, even those agencies which did not complete Round 1 and receive one-on-one education from the MAC before that round was suspended.

Lolley said Palmetto provided the following  statement to a home health coalition request for clarification about agencies which did not receive one-on-one instruction : “Providers are being progressed if they did not request education on or before their due date. We have a number of providers that missed their deadline to request education, so yes, there is a chance that they have been progressed before they are receiving their education.“

Focus on the F2F

“Mac reviewers will be looking at the claims to ensure that agencies are in compliance with Medicare eligibility and payment requirements,“ said J’non Griffin, owner of Home Health Solutions.  “In Round 1, a substantial number of agencies had problems with the Face-to-Face.”

Additional concerns included a lack of specific orders for therapy and services, omissions and inconsistencies in documentation, but the Face-to-Face was one of the most troublesome areas for agencies, she said.

“Agencies which have not yet received training in the Face-to-Face should make doing so a priority,” J’non said.

J’non will offer an online audio training session titled “Make the Face-to-Face Count” next Thursday, July 13, reviewing valid and invalid F2F items pulled from actual charts, and discussing specific methodologies.  For details, click here.

Hospice agencies may be interested in an online audio training program titled “Improving Hospice Documentation,” presented by HHS Special Projects Director Heather Calhoun on Tuesday, July 11.  For details, click here. 

The 16 states in the Palmetto GBA area include Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, New Mexico, Illinois, Indiana, Ohio, Oklahoma, North Carolina, South Carolina, Tennessee, and Texas.

How your home health agency can avoid ADRs


EDITOR’S NOTE: This article is reprinted from the July issue of The Absolute Agency, a free monthly best practices guide for home health agencies published by Home Health Solutions. Click here if you’d like to subscribe.

You’ve read and re-read your claim before submitting it, and you have all the documentation in place – but there it is: the dreaded request for additional documentation.

First of all, don’t panic.

 An ADR does not necessarily mean your agency has done anything wrong. Many things outside your agency’s control can trigger these requests, including probes or edits that are service-specific, provider-specific, beneficiary-specific or diagnosis driven. In many cases the OASIS will trigger a frequently-abused HIPPS code.

If you really have done your homework, evaluating and scoring your patients according to Medicare’s own definitions and supplementing the OASIS with high quality clinical notes and assessments, your ADR experience is likely to be much less stressful.

You may simply need to do a better job of connecting the dots for the MAC reviewer by providing information that was inadvertently omitted, or pointing out documentation the busy reviewer overlooked.

 “Try to look at any ADR as a learning experience that can sharpen your documentation skills, identify weaknesses in your operation and shore up your processes to protect against future ADRs,” advises J’non Griffin, owner of Home Health Solutions.

   Sometimes, of course, it’s more than the luck of the draw that attracts ADRs. Agencies make mistakes. OASIS scores aren’t well supported, or call into question the patient’s homebound status, phraseology is vague or subjective rather than clinical, and it’s difficult to tell what’s actually going on with the patient’s condition.

When the agency has not clearly documented from the beginning, attempting to sort through the confusion can turn into a time-consuming bout of evidence-collecting and careful explanation.

J’non and the HHS team have helped agencies of all sizes across the country successfully respond to ADRs, and they have identified a few of the Red Flags likely to capture the notice of MACs. The good news is that agencies can address many of these risk areas before submitting claims just by carefully reviewing documentation.

“There’s no magic deterrent to protect any agency, but you can take steps to insulate yourself by being aware of certain triggers and becoming proactive about avoiding these errors or improving documentation in these areas,” J’non says.

SOME ADR TRIGGERS

   Here are some of the trouble areas that can trigger an ADR for an agency:

– Contradictory answers on the OASIS
– Inadequate Face-to-Face documentation
– Multiple re-certifications
-Recertifying when there is no new or exacerbated diagnosis in the record
– Recertifying for a “later episode”
– Minor treatment changes that do not support medical necessity
– No evidence of a continuing need for skilled care
– Multiple episodes of observation and assessment of chronic con
ditions.
– Repetitive education or education that does not address a knowledge deficit
– Discharges followed by re-admissions without any intervening change in the patient’s condition
– Inconsistencies in patient treatment

 

TIPS FOR RESPONDING TO ADRs

   When your agency has received an ADR, these tips may help you complete it in a timely and thorough manner:

  •  Look at the ADR due date and mark it on a calendar. With a limited response time, it is imperative to complete your information gathering tasks by the deadline. We recommend setting a target date for submitting your response prior to the actual due date to ensure timeliness.
  • Use a team approach to address the ADR. Nursing, therapy and medical records will likely need to work together to review and collect the data needed.
  • Carefully review the ADR and note each piece of requested documentation. There’s no better way than an old-fashioned checklist to make certain that you are addressing each request.
  •  Additional documentation which has not been requested may be provided to support payment of the claim. Signed and dated physician certifications, for example, may not be on the list of requested documentation in an ADR, but this is a foundational piece for establishing the validity of your claim.
  • On the other hand, do not make the mistake of overloading the reviewer with too much documentation. A file bulging with too much information, particularly information which was not requested, will not be happily received by an overloaded reviewer behind in his or her cases. Choose your evidence wisely, based on the strength it adds to your case.
  • Resist the urge to alter or attempt to correct any original documentation. Explain and supplement to make your case stronger.
  •  Assemble all documents in order of request. Your goal is to make the process as easy as possible for the reviewer, and providing the information in a manner that is easy to sort through will be helpful. Some agencies use page numbers specific to the particular case. Others identify documentation pages with highlighted text, or provide an index. There is no right or wrong way — but your submission must be easy for the reviewer to figure out.
  • Create a persuasive Cover Letter. This is arguably the most important part of your response. The Cover Letter will justify the care delivered by your agency and briefly tell the reviewer what supportive documentation is being submitted and how to easily find it. Don’t make the Cover Letter too long. It should briefly summarize the patient’s needs, the skilled services provided to meet those needs, and the patient’s response/progress. Make it as easy to read as possible. No one likes to read two pages of text unbroken by paragraphs! Use bulleted points, and consider adding some bold-faced titles to help the reviewer quickly scan the material. See how we have used bold-faced titles such as “Some ADR Triggers” and “Tips for Responding” here to break up the text? You may wish to do the same thing in your Cover Letter with helpful titles such as “What We’re Submitting” or “Skilled Services We Provided.”
  • Keep a copy of all documents submitted to the Contractor.
     

    NEED HELP WITH YOUR ADRs?

   ADRs are intimidating and time-consuming. Sometimes, the surest way to navigate an ADR is to turn to an experienced clinical consultant who can guide you through the process, make certain that you include all the key elements needed to support your claim.
The consultant can also show you how to make process improvements to reduce the risk of future ADRs or claim denials.
Home Health Solutions can provide the support you need to take the pain out of the ADR process. If you’d like more information about our ADR services, call us at 888-418-6970 or email:
tiffany@homehealthsolutionsllc.com

 

Release of Guidelines gives ‘green light’ for agencies to proceed with Emergency Plans

Has your home health agency been waiting on Interpretive Guidelines for new Medicare Conditions of Participation before beginning work on an Emergency Preparedness Program?

Then it’s time to roll up your sleeves and dive into identifying the specific hazardous situations your agency could face, develop emergency communication strategies for emergency conditions, and create the training and testing procedures which must be in place by November.

Interpretive Guidelines have been released by the Centers for Medicare and Medicaid Services (CMS), specifying what Surveyors will look for after Nov. 15 as they try to determine how well agencies have prepared to address the needs of homebound patients in the event of manmade or natural disasters.

“There were no real surprises in the Interpretive Guidelines,” said Home Health Solutions owner J’non Griffin. “These guidelines simply confirm what Surveyors will be looking at when they evaluate agency Emergency Preparedness Programs.”

The real impact of the release of the Interpretive Guidelines is that agencies may now believe they have a “green light” to go forward with work on their plans, J’non said.

“Even though CMS has encouraged agencies to avoid waiting on the release of the Guidelines to get started on their Emergency Plans or risk being cited for non-compliance in November, some agencies felt that until the Guidelines were in place, there was no real sense of urgency,” she said.

“Now we are just five months away, and there’s no more time left to delay,” J’non said.

She said it will take some time for agencies to effectively coordinate efforts with strategic community partners to plan and stage the community-wide disaster drill which is an important part of the CoPs requirement.

What Surveyors will look for

Based on the newly-released Guidelines, here’s what agencies can expect, during Survey:

  • Surveyors will review records to look for some specific items, including evidence that the agency has met a new Condition of Participation requiring an individual emergency plan for each patient as part of the comprehensive assessment.
  • They’ll look for documentation showing that agency personnel discussed emergency procedures with patients and caregivers.
  • Agencies will need written policies and procedures detailing how emergencies will be handled.
     
  • Surveyors will be especially interested in seeing written procedures for how agencies will inform state and local officials about patients who may need evacuation from their residences.
  •  It is also like that Surveyors will interview agency leaders and/or staff members to determine how knowledgeable they are about procedures to be followed in an emergency situation.

 HHS can help!

Our 12-step Emergency Preparedness Plan Assembly Kit makes compliance easy for your agency. We break down the complicated process into easy-to-follow steps, show you what a completed Plan should look like, and provide more than 30 forms and tools designed to capture all the information you’ll need to put together your own plan – even the training materials and evaluation forms to meet the testing/training requirement.

Our Kit provides the full written policies and procedures your agency will be required to have — and now that the Interpretive Guidelines have been released, we are adding tips on what Surveyors will want to see.

Click here to visit The Solutions Shop, our online store, and order the Kit today!

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.

  1. IDENTIFY YOUR AGENCY’S SPECIFIC RISKS.
    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.
  2. MAKE INFECTION CONTROL TRAINING PART OF YOUR AGENCY’S ORIENTATION.
    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.
  3. DEVOTE ENOUGH TIME TO TRAINING.
    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.
  4. KEEP RECORDS.
    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.
  5. REQUIRE SIGNATURES.
    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.

  6. EVALUATE AND UPDATE YOUR TRAINING PROGRAM AT LEAST ANNUALLY.
    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.

Our CoPs COMPANION puts a trusted industry expert at your side

We’ve sifted through all the new Conditions of Participation, thought about how best to help you apply the new requirements in your home health agency’s operation, and the result is the CoPs COMPANION, four books filled with helpful charts, tools and detailed information about each aspect of the administrative, operational and procedural changes ahead for the home health field.

Take a look at just a few of the highlights:

In Volume I: We detail all your new responsibilities, from Start of Care right through Transfer and Discharge. You’ll find helpful charts showing which information must be given to who, and on what schedule, as well as what to include in the new Transfer or Discharge Summary you’ll have to prepare. We also offer a helpful tool for making the decision about whether to re-certify or discharge a patient.

In Volume II: We list the “checkpoints” for when you’ll need to notify the physician or conference with the interdisciplinary team to meet new care coordination requirements. You’ll read about the role of the new Clinical Manager, and see a job description. We also explain how to meet new requirements for patient participation in the development of care plans.

In Volume III: We’ve put together a step-by-step guide to take the mystery out of QAPI, and our helpful documentation worksheet will walk you through how to create reports detailing your agency’s PIPs. Since the Infection Control program required by CoPs will need to be an integral part of your agency’s QAPI program, we’ve featured it here, too.

In Volume IV:  We show you how and why CMS is demanding more accountability from home health agencies – from very specific new demands on the governing body to higher standards for agency administrators.

And this is just SOME of the helpful information we’ve packed into this informational series.

It’s  designed to put a trusted industry expert at your side through the transition process,  making compliance easy!

At less than $60 per book, how can you afford NOT to have this detailed reference series?

Click here to visit The Solutions Shop now to check out this 4-volume series plus all our other helpful CoPs products.

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: www.homehealthsolutionsllc.com/solutions-shop

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:

https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertEmergPrep/Emergency-Prep-Rule.html.

CMS announcement did not mention Emergency Preparedness Plans

 Good news, bad news

There’s good news in the home health field this week:

Yes, there is a possibility that the federal Center for Medicare and Medicaid Services will delay the implementation of revised Conditions of Participation, allowing home health agencies extra time to make the many clinical, organizational and administrative changes which will be required.

The bad news is that a possible delay doesn’t mean agencies can afford to wait to begin working on meeting the new requirements.

In fact, Home Health Solutions Owner and President J’non Griffin advises home health agencies to move forward with all changes as if there will be no change in the effective date established under current law.

The need to begin work now on the many changes required under CoPs is especially true for creating Emergency Preparedness Plans, which will likely be one of the more labor-intensive and intimidating new requirements for agencies, J’non said.

Conditions of Participation will require home health agencies to have in place a detailed Emergency Preparedness Plan including hazard risk assessments for their specific communities, communication plans for any natural or man-made disaster and many other specific components.

Under the Final Rule approved in January, agencies have until November 2017 to put together this complex Emergency Preparation Plan, and have in place measures for conducting community-coordinated disaster drills to practice how they would handle their patients and work with other facilities during an actual emergency situation. In addition, the agency’s emergency preparedness program will need to include individual plans for its patients.

Last week’s announcement by CMS that it will consider a delayed start date for CoPs, pushing the current effective date from July 13 2017 to January 13 2018 made no mention of a new time frame for the Emergency Preparedness Plan requirement.

Until otherwise notified, agencies must assume that the November  2017 deadline stands, according to Home Health Solutions LLC Owner and President J’non Griffin.

There is no guarantee that CMS will approve any delays, despite last week’s announcement, and agencies could be risking non-compliance if they do not move forward with changes, J’non said.
“CMS has opened a 60-day public comment period to solicit information it will use in making the determination about whether to delay the start date for CoPs,” J’non said. “But it is important to remember that if the start date is not delayed at the end of the 60-day period, agencies which have not begun to make the necessary changes will not have enough time to do so by July 13.”

Need help with your Emergency Plan?

A complete Emergency Preparedness Plan Assembly Kit is one of the resources and products Home Health Solutions has created to help agencies meet the new CoPs.

The Assembly Kit and other products are featured in our new CoPs Success Catalog.  Click here to see the catalog now.

Other helpful products:
   – A complete video library overviewing new CoPs
  –  A 4-Volume Reference Guide
   – Tutorials for Home Health Aides on new requirements
   – An innovative new Patient Orientation Package which is customized for your agency 
   – Complete, done-for-you policy manuals

  You’ll find all the tools you need to meet the new CoPs in our catalog. And with our CoPs Success Bundle, you can buy EVERYTHING you need for success at one great price, without having to spend the time to pick and choose. We’ve done all the work for you! 

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.

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!

What’s next for home health? Experts at conference admit they’re baffled

In a week of intense debate in the nation’s capital over efforts to repeal and replace Obamacare, the future of myriad home health regulations remains as uncertain as other health care issues. 

But one thing IS certain, according to Home Health Care Solutions owner J’non Griffin, who joined other home health experts at the 2017 Illinois Home Care and Hospice Conference & Exhibition near Chicago this week. Whether lawmakers change, repeal or leave in place existing Medicare requirements, agencies must continue to streamline their processes and focus on quality improvements to remain profitable in the increasingly challenging home health  field. 

Agencies in Florida hoping for a reprieve from an April 1 rollout of pre-claim reviews by the Centers for Medicare and Medicaid Services are likely to be disappointed, according to keynote speaker William Dombi, who serves as The National Home Care Association’s Vice-President  for Law. 

The eyes of the nation remain fixed on the D.C. debate over replacing the Affordable Health Care Act with an as-yet-unnamed plan which has been alternately dubbed Trumpcare,  Ryancare and Obamacare Lite. How the proposed replacement would impact home health has not yet been determined.

Meanwhile, the clock ticks inexorably toward the April 1 deadline in Florida, leaving little time or attention for NACH’s efforts to derail PCRs.

“The Washington perspective is that we are all crazy at this time. No one knows at all,” Dombi told hundreds of home health professionals attending the Illinois conference. “My concern is that day after day, hope of something in Florida diminishes.” 

NAHC has prioritized stopping the PCR process in additional states, including Florida, and curtailing the process in Illinois, which became the first state to undergo a PCR demonstration in August, 2016. Dombi said NACH is petitioning CMS to allow agencies which have had consistently high affirmation rates to opt out of the PCR process without being penalized financially. 

But NAHC’s efforts to get lawmakers to support the repeal of PCRs have been largely overshadowed by the bigger repeal efforts on Capitol Hill, and the political fallout. Republican lawmakers unveiled the replacement health care act promised by the Trump administration this week to major discord in Washington D.C., with condemnation from Democrats, the American Medical Association, the American Hospital Association, and even some Republicans. 

What will happen next is anyone’s guess, Dombi told conference attendees. He describes the situation as “very chaotic.” 

As federal lawmakers grapple with complex issues such as the extent of individual rights to health care, whether responsibility for health care is a federal or state priority and whether the role of the government in health care should be as partner or provider,  Dombi sees some areas of hope on the horizon for home health. 

The new administration’s Secretary of  Health and Human Services, Tom Price, has a sound grasp of many home health concerns and a history of support for many of them, Dombi said. 

Price has indicated some support for delaying new Conditions of Participation for Medicare which are scheduled to become effective July 13, Dombi said.  The new CoPs will require many operational changes for home health agencies, and there is some concern within the industry that there is not enough time for agencies to fully implement all the changes.

With no interpretive guidelines released four months away from the implementation,  NAHC believes surveyors aren’t ready for new CoPs and has been lobbying for a delay. Word in D.C. is that Price is “seriously considering” NAHC’s position, according  to Dombi.

However, it is important to note that no delays of PCRs or CoPs have been approved at this time. Industry experts at the Illinois conference strongly encouraged agencies to proceed as if new Conditions of Participation, Pre-Claim Reviews and Value Based Purchasing initiatives (in which agencies are rewarded or penalized depending on how well they make improvements) are inevitable. 

No one knows if or when or where CMS will expand Value-Based Initiatives beyond the nine states in the current trial, whether PCRs will proceed to other states after the Florida rollout, or exactly what will happen next in home health, but agencies must be prepared anyway, PPS Plus educator Jennifer Warfield told her conference audience.

“Even if the actual term Value Based Purchasing goes away, the future of your agency is always going to be tied to its improvement processes,” she said. 

Joyce Ryan Boin with Strategic Health Care  Solutions encouraged agencies to redirect their focus toward education and ongoing strategy for measurable improvement. 

“We’re not in Kanas any more,” she said. 

 EDITOR’S NOTE:  Check out HHS Owner J’non Griffin’s four-part webinar series on the new Conditions of Participation, providing an overview and highlighting compliance strategies for agencies to develop a QAPI program. The series begins March 15 at 10:30 a.m. CT, and will continue March 29, April 11 and April 25. 
For details or to register, click here.