Tag Archives: Home health agencies

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.

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.
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.
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.
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.
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.
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.

Conditions of Participation, Home health agencies, Uncategorized

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

April 27, 2017 HHSolutions

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.

Conditions of Participation, Home Health News

CMS announcement did not mention Emergency Preparedness Plans

April 5, 2017 HHSolutions

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!

Conditions of Participation, Home health agencies, Uncategorized

What PCR reprieves, CoPs delay could mean

April 4, 2017 HHSolutions

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.

Conditions of Participation, Home health agencies, Home health management

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

March 13, 2017 HHSolutions

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!

Home health agencies, Home Health News, Pre-claim reviews

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

March 10, 2017 HHSolutions

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.

Home health management

Three steps to take when your home health referrals drop

December 12, 2016 HHSolutions

BY JASON LEWALLEN

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.
Sales 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.

Coding, Home health agencies

Outsourcing: Tips for choosing the right partner

November 15, 2016 HHSolutions

Economics of Change

Editor’s Note: Jason Lewallen is Director of Sales and Marketing for Home Health Solutions and a noted speaker, blogger and author in the home health field. This article first appeared in SOLUTIONS, the monthly e-newsletter from HHS.

By JASON LEWALLEN

Outsourcing is a hotly debated issue in the home health and hospice industry. Home health agencies know they need to narrow their margins while maximizing their reimbursement, but historically, it has been thought to be more beneficial to have a person on staff to handle each part of the process. This especially applies when it comes to clinical matters. Legal risks, privacy concerns and the delicate nature of our business makes us wary about trusting another entity with these matters.

Whether outsourcing is the right option for your home health agency depends largely on how you answer the following questions.

Do you really need a specialist?

In a fluid health care market where guidance changes frequently, regulatory demands are constantly evolving and penalties are formidable, agencies recognize the indisputable value of staying fully informed and well trained. Even so, agency leaders often struggle to justify hiring specialized services. The simple fact is you would not ask a plastic surgeon to treat cardiac issues. Even as a legally practicing physician with a medical background that encompasses many of the basic concepts of how the heart works, the plastic surgeon lacks the specialized training needed to adequately address the cardiovascular system. The best results could be expected from the cardiac specialist.

The same logic applies to obtaining the best results for your home health agency by outsourcing coding services. The best clinical consultants who handle coding and OASIS review are uniquely trained to maximize your reimbursement and reduce your compliance risk.

How will outsourcing affect reimbursement?

The difference in reimbursement when switching from in-house coding to outsource coding varies from agency to agency. There is always a chance that you have an optimized coding team who can deliver optimum results, although that is not what is commonly discovered. A reputable provider will work with you to evaluate whether you are achieving the maximum reimbursement that you are due. Remember, this is money that you should be receiving when there are no coding errors.

While averages vary, most outsourcing partners can generate $200-$300 per chart for a majority of their clients simply by correcting coding errors and helping review the OASIS to ensure compliance. At a loss of just $100 per chart, an agency might be looking at $20,000 in recovered losses for just 200 patients. Outsourcing has other benefits in addition to making agencies more profitable. It frees agencies from worrying about benefits, sick days, or performance issues.

Can you trust the specialist?

This can be a loaded inquiry. We’ve all known a few subpar medical professionals, and frankly there are coding firms which do not perform at the necessary level of expertise. Having a partner who will ensure that you get the full reimbursement due to your agency for each episode is critical.

Choosing the right one requires knowing what to look for and what to avoid.

Here are a few tips:

The right firm will have credentials, experience and a reputation in the industry for consistent performance. It will offer a demonstrable commitment to monitoring industry regulations and providing the support you need for clinical and financial success.
Look for a firm headed by a confident, approachable coach who is in demand as a leader and teacher in the industry and can build a solid case for increased outcomes for your agency.
Verify that you are working with a team of experienced clinicians who know how to evaluate a clinical narrative. Some outsourced coding providers will certify non-clinical individuals to save money. In the long run, this can damage the integrity of your organization and more often can help to drive down your outcomes scores as well as your reimbursement.
Another valuable area to explore the process and ease of accessibility. Some outsource providers will require you to scan or fax mass amounts of information or have a long series of steps that make working with them seem like you are working for them. Others will not be able to guarantee that you will receive your work in a timely fashion. These days, the best providers can actually work within your electronic medical record (EHR) system to improve the timeliness of chart completion while minimizing the work required of clients.Regularly scheduled reviews to evaluate your coding and OASIS for optimization can help you determine whether an in-house coding specialist or an outsourcing partner may be the more viable and cost-efficient solution. Your agency may well have the top-notch coding talent that is helping you get the maximum reimbursement, but in today’s home health market, can anyone afford not to be sure?

Home health agencies

Top Four Fall Priorities for Home Health Agencies

October 22, 2016 HHSolutions

Where is your home health agency’s focus this fall?
Smart home health agencies are focusing their efforts on housekeeping, trying to shore up bottom lines by rectifying errors and inconsistencies that result in costly claims denials, and scheduling crucial training for all agency staff.
The four cornerstones for success in today’s home care market are training, internal reviews and audits , preparation and streamlining operations, according to Home Health Solutions owner and president J’non Griffin.
If your agency isn’t working on at least one of these areas right now, it’s losing ground in the effort to stay abreast of industry regulations and maintain clinical and financial success.

Training

Did you know home health agencies lose, on average, $200 to $300 per episode to coding and OASIS errors?
The money agencies spend on staff training is more than recouped in improved performance of its employees. Home Health Solutions provides convenient online training courses available through our online store for continuing education credits.
But we realize not every agency has the same training needs, so we also work with agencies to provide customized training and education.
Our goal is to provide the solutions your agency needs. Contact us today to talk about how we can help you.

Self audits and review

The goblins and gremlins may not getcha this Halloween season, but the glitches sure will. Errors and inconsistencies are the hobgoblins of the home health field, resulting in costly claims denials , Survey issues and more.
Smart home health agencies are conducting self reviews and analysis on every level to find glitches before surveyors do. But there’s only so much time in a day — and it’s often hard to be objective about self evaluation.
Our Mock Audits are the resource agencies need to experience firsthand the same thorough investigation a real Survey would bring, allowing agencies to clean up errors before there are costly consequences. Click here for details about the value of a Mock Audit.

Preparation

When CMS suspended rollouts of pre-claim reviews after a disastrous initial experience in Illinois, home heath agencies breathed a collective sigh of relief.
But the reprieve is only temporary, and smart agencies are using the extra time to get prepared.
From Value-Based Purchasing to pre-claim reviews, a new way of doing business is on the horizon for home health agencies, and meeting the new requirements is going to take a strong commitment to adequate preparation.
Here’s an easy and inexpensive first step for agencies looking ahead to pre-claim reviews:
Order our DIY Pre-Claim Review Preparation Kit for just $25. It’s the compass your agency needs to get started on the road to preparation.

Outsourcing

Compliance is costly.
It takes time, manpower and relentless commitment on the part of home health agencies to stay up-to-date on current regulations — and it can’t come at the expense of an agency’s primary focus on patient care.
More and more agencies are determining that the most cost-effective means of doing business is to outsource all or some portion of operations. And we’re not just talking about coding, OASIS or billing. Some agencies need help with specific aspects such as developing POCs, handling ADRs or service specific probe reviews.
We can help.
No matter what your need is, we have the solution.
Give us a call today at 888-418-6970 and see what we can do for you.

home health documentation, Home Health News

The value of a Mock Audit: Why home health agencies need to do this

October 12, 2016 HHSolutions

It may be the season for goblins and gremlins, but in an era of unprecedented regulatory scrutiny for the home health field, it’s the glitches home health agencies really need to worry about.
Errors, oversights, and inconsistencies are the hobgoblins of the home health industry, carrying high price tags in the form of claims denials – or, even more frightening, fraud investigations and hefty fines.
And, to frame things in the spirit of the season, the scary shadow of scrutiny is looming larger.
The future of home health is filled with quality improvement requirements that have not yet been fully determined to be either tricks or treats, but home health professionals know they’re coming, sooner or later. From value-based purchasing to pre-claim reviews and a proposed new Condition of Participation for Medicare, agencies are feeling the squeeze to reduce errors and improve performance.
There’s pressure to become faster as well as better. While the Centers for Medicare and Medicaid Services has temporarily delayed rollouts of pre-claim reviews to give agencies more time to prepare, home health experts agree, by and large, that the eventual implementation will force agencies to speed up as well as fine-tune their processes.

Let’s go glitch hunting

This season, Home Health Solutions owner and president J’non Griffin recommends agencies who are serious about success take a broom, figuratively speaking, to the cobwebs and shine a light into every dark nook and cranny, to ferret out the vulnerabilities in the operation and take corrective action.
“Smart agencies are doing everything they can right now to mitigate risk,” J’non says. “They’re honing in on the quality of their documentation, reviewing clinical notes made by nurses and therapists, prioritizing internal audits and quality reviews, and following up with extra training measures to address any shortfalls.”
Done well, self-assessment takes extra time, and for an agency already struggling under clinical and operational demands, creating the time for self-evaluation can seem like an overwhelming task. It’s hard to remain objective and easy to overlook crucial details that surveyors won’t miss.
Many agencies are finding the solution is to rely on outside firms to provide the thorough and objective assessment needed to identify compliance risks and provide a plan of remedy.

What does a Mock Audit entail?

From identifying expired items in an agency’s supply closet to revealing inaccuracies in its personnel files, a Mock Audit can be a comprehensive tool for determining exactly where an agency is headed for trouble.
It’s conducted exactly as surveyors would conduct the real thing; once scheduled, there’s no advance notice given to staff.
A team spends 1-3 days on site, depending on the size of the agency being audited, with some team members remaining in the office to audit charts and personnel files while other team members conduct home visits in all disciplines.
An exit interview concludes the process, and the findings are shared with the administrator along with recommendations for improvement so that a plan of correction may be implemented. Education tailored to address specific deficiencies can be arranged.
“A Mock Audit gives the agency staff an opportunity to practice for the real thing so that they will have an idea of the survey process, whether it be state Survey or advanced accreditation,” says Heather Calhoun, Director of Special Appeals and Project Management at HHS.
She recommends agencies schedule an annual Mock Audit to help control compliance risks.
“There’s no better way for an agency to determine areas of weakness and potential risk,” Heather says.
Jason Lewallen, Director of Sales and Marketing at HHS, agrees.
“With the rapid pace of regulatory change, agencies face an uphill battle when preparing for a survey,” Jason says. “This industry is fortunate that there are programs in place that can minimize the risk of penalty before the surveyor arrives.”
Findings can result in financial gain to agencies, because audits often identify specific areas of improper documentation that result in claims denials.
“Mock Audits offer agencies the opportunity to fix errors before the organization is negatively affected by claims denials as well as accreditation or state Survey,” Jason says.
The cost of the audit, like its duration, depends on the size of the agency and a few other variables. Give HHS a call today to discuss how a Mock Audit can help shore up your operation, and put your agency on the road to success this fall.

HHS Blog

Tag Archives: Home health agencies