Tag Archives: home health

What LHC, Almost Family Merger Means for the Home Health Industry

A $2.4 billion merger between two powerhouses in the home health field is expected to create a new industry giant and set in motion significant long-term consequences for the home health field, according to Home Health Solutions Owner and President J’non Griffin.

In a deal set to close in 2018, Kentucky-based Almost Family, Inc., and Louisiana-based LHC Group, Inc, have announced their plans for an all-stock merger of equals, creating a company with a starting roster of more than 30,000 employees nationwide.

“This merger is a huge development, with the potential to shore up confidence in the future of home health, impact stocks and rejuvenate an industry feeling the weight of an increasing regulatory burden,” J’non said.

But she warns that the move could have some negative consequences – especially for smaller agencies.

“The new company created by this merger will be poised to set the professional tone and standards in the entire industry regarding delivery of well-coordinated, patient-centered care,” J’non said.

“Smaller agencies struggling to meet quality expectations may find it increasingly hard to compete in the evolving marketplace. Coupled with increasing regulations, the evolution of a faster-paced, coordination-intensive market with much bigger players could squeeze some smaller, struggling agencies into selling or going out of business,“ she added.

Expect more buyouts and partnerships

The merger between LHC and Almost Family reflects a dramatically shifting turf in the industry, as agencies increasingly look at strategic partnerships, joint ventures and other consolidation efforts to buffer the challenges presented by mounting regulatory burdens.

“Buyouts and partnerships are a growing trend,” J’non said. “We can expect to see increasing numbers as agencies work out innovative answers to the demands for quality outcomes, expedited turnarounds, increasing care coordination, and value-based reimbursement.”

So far this year, LHC Group had acquired more than 35 home health, hospice or community-based locations, as well as six long-term acute care hospital operations, before it announced plans for the merger with Almost Family.

2018: A ‘transformative’ year ahead

Next year is shaping up to be a transformative year in many ways for the home health field, according to J’non. In January, agencies will implement new Conditions of Participation set by the Centers for Medicare and Medicaid Services (CMS), requiring extensive operational, administrative and clinical changes.

“Meeting the demands of the new CoPs is expected to be a watershed moment for some agencies which have been struggling to stay afloat under the compliance burden, and simply may not be able to adapt quickly enough to the new round of regulations,” she said.

Does your agency
need CoPs training?
Click here to read about
J’non’s Dec. 16 seminar
in Vegas!

In addition to new CoPs requirements, agencies throughout the country are expected to be required to transition soon to the value-based reimbursement model already under demonstration in nine states.

Coming soon: Value-based purchasing

Officials at Almost Family and LHC have made no bones about positioning the giant company created by the merger to become the industry leader in value-based reimbursement.

Although a value-based purchasing model is only active in nine states right now, many home health experts believe CMS may have recently signaled its readiness to soon expand VBP to all other states.

“CMS did not really make many adjustments to the value-based purchasing in the 2018 Payment Rule, and the changes that were made were not really significant changes,” J’non said. “That may well indicate that CMS believes the model is ready for a full-scale release.”

The VBP model has largely been considered a success because the nine states participating in the demonstration have seen improvements in outcomes at a faster rate than states which were not included in the program, J’non said.

CMS requires two exercises before November deadline

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-day Countdown to Emergency Preparedness and comment to win helpful EP products! 

WEDNESDAY Oct. 18 Giveaway

Are you still working hard to get your home health agency’s new Emergency Preparedness Program in place by November so that you can meet the CMS deadline and begin all the detailed planning for those two exercises you’re required to stage — the full-scale community disaster drill and a second, smaller-scale  table-top exercise?

We sure hope not.

For compliance, your agency will need to have already staged both these required exercises by November. The Emergency Preparedness Requirements Final Rule was posted to the Federal Register more than a year ago, on Sept. 8, 2016, and the regulation went into effect just two months later, on Nov. 16, 2016. Medicare and Medicaid Participating Providers and Suppliers were given one year from the effective date to comply and implement all regulations. When that year is up – in just one more month – home health agencies will be subject to citations for non-compliance if they have not yet staged both exercises this past year.

The Emergency Preparedness Requirement was confusing to many home health agencies. We talk to agencies every day who are so busy caring for patients and taking care of agency business that they have trouble juggling regulatory deadlines – especially this year, when the start date for new Conditions of Participation was originally set for a July implementation, and then delayed until January.

Isn’t the Emergency Preparedness requirement part of the new CoPs, agencies ask us. Don’t we have until January now? Not for your Emergency Preparedness Programs, we explain.

While the Emergency Preparedness requirement is included as part of the new CoPs, and while  the start date for CoPs was pushed back six months, a delay was never granted for the original Emergency Preparedness Requirements Final Rule which posted to the Federal Register back in 2016.

The clock began ticking then.

Time is up.

Some agencies which experienced actual emergencies this year may be exempt from the community-wide disaster drill (please see Tuesday’s Tip #2).

But agencies which did not activate emergency plans this year and conduct an evaluation afterward are expected to comply with the full-scale community-wide drill prior to next month’s deadline.

In either case, agencies also will be expected to have staged tabletop exercises, in which mock disasters are conducted via paper.

If you’re feeling panicked by the approaching deadline, please visit our online store today and check out our 12-step Emergency Preparedness Plan Assembly Kit. We’re not going to mislead you; it’s getting late in the game to comply, and it will be very difficult now to meet the deadline if you have not yet begun. But don’t wait another day. Our Kit will make it faster and easier.

Click here to visit The Solutions Shop, our online store. 


HHS Countdown to Emergency Preparedness offers tips and giveaways

Look for this picture on the Home Health Solutions Facebook Page every day during our 10-Day Countdown to Emergency Preparedness and comment to win helpful EP products! 

Tip #1:  Are your patients prepared?
MONDAY OCT. 16 GIVEAWAY: Our helpful EP Guide to Survey Readiness

CMS wants to make certain home health agencies have adequately prepared patients and their caregivers for the possibility of evacuation or other possible changes in the delivery of care during or immediately after an emergency situation.

One of the ways agencies should do this is by providing patients two lists: a Medication List and a Special Equipment List. These lists are to be kept in the home and constantly updated so that each list is always current. This means it will be necessary to review and update the Medication List at each visit – a big change for most agencies.

Make certain patients and caregivers understand that these lists are to go with them to a shelter if an evacuation is needed.

The Medication List should include the medication, dose, frequency, route, time of day, and any special considerations for administration. The Special Equipment List will identify the equipment needs of the patient.

Note that lists should include the name and phone number of the patient’s physician and pharmacy, and the address of the pharmacy should also be included.

It is also important to include allergies and adverse events as well the name and contact information for the home health agency on these lists.

During the confusion of an emergency situation, this information could be vital to maintain continuity of care for the patient.  HHS recommends that your agency create a form to be used to collect all the necessary information, so that nothing will be inadvertently omitted.

Be sure to document your discussions with patient and caregivers about the importance of these lists, with reminders that the lists should always travel with the patient if there is an evacuation.

Preparing homebound patients for the possibility of an emergency situation is an important step in your agency’s overall Emergency Preparedness Program. 

Read more tips and enter to win daily giveaways on the Home Health Solutions Facebook Page during our “10-Day Countdown to Emergency Preparedness,” as we help home health agencies meet the CMS deadline to have Emergency Preparedness Programs in place. 

Will HHGM be delayed?

House bill would delay new payment model until 2020,
but agencies still have work to do. Here are 3 priorities.

It’s been a year of remarkable regulatory suspensions and delays for the home health industry – sometimes at the last minute  – and home health agencies are wondering whether another regulatory reprieve could be in the works.

A bill introduced late last week in the U.S. House of Representatives would postpone the costly and controversial overhaul of the Medicare payment system known as the Home Health Groupings Model (HHGM) which CMS proposes to implement in 2019.

Agencies would not see implementation of the proposed HHGM until 2020 under HR 3992, the bill introduced last Friday by Rep. Kristi Noem (R) of South Dakota.

“But it is important to note that the bill in its current form will not address expected losses of as much as $950 million in the first year of implementation due to reduced payments to home health agencies,” said J’non Griffin, owner and president of Home Health Solutions.

HR 3993, or the Rural Home Health Extension and Regulatory Relief Act, does not affect the proposed new 30-day payment episode in the HHGM or the shift away from a therapy-driven payment model to a new system which relies on clinical groupings, J’non said.

“Whether it is implemented in 2019 or a year later, under this proposed bill, the new payment system will still be a coding and OASIS driven payment model,” J’non said. “With that in mind, agencies can begin some important preparations.” She recommends that agencies take the following 3 steps to prepare:

  1. Focus on improved coding accuracy. 

The new HHGM relies heavily on primary diagnoses codes to classify each 30-day episode into one of six clinical groupings. Comorbidities, early or late timing of the episode, admission source and the patient’s cognitive and functional status are also integral to the new classification.

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

Whether agencies rely on in-house coders or outsource coding services, the quality of an agency’s coding will determine its viability under the HHGM, J’non said.

“Some agencies which may have been reluctant to outsource coding services are going to have to make that move, under the new HHGM, to ensure the level of accuracy needed for success, “she said. “And that decision is going to open up new areas of compliance risk, requiring agencies to look beyond cost to determine the credentials of the coders and quality of the services provided. It’s definitely a case of buyer beware in the coding world. If the price seems to be an exceptional bargain, smart agencies should wonder how and ask why.”

2. Provide thorough OASIS C-2 training to all team members.

As part of the HHGM case-mix adjustment, CMS proposes to assign points for each of the responses to certain OASIS functional items. The sum of those points would create a functional score for the period of care. Items to be scored are:

● M1800: Grooming.

● M1810: Current Ability to Dress Upper Body.

● M1820: Current Ability to Dress Lower Body.

● M1830: Bathing.

● M1840: Toilet Transferring.

● M1850: Transferring.

● M1860: Ambulation/Locomotion.

● M1032 (M1033 in OASIS-C1): Risk of Hospitalization.

“OASIS mistakes will be costly under the new HHGM,” J’non warns. “Agencies which may have been reluctant to invest in OASIS training in the past need to make that commitment now. It’s important to note, too, that just because clinicians have had training in the past doesn’t necessarily mean they’re up to speed. Guidance changes frequently in this field – and complete reversals are not unusual. Accuracy requires ongoing training.  Training does pay for itself, directly impacting an agency’s bottom line.”

3. Estimate the HHGM impact on your agency by using a CMS tool.

Determining how the HHGM will impact your agency is a crucial first step in developing plans to stabilize your bottom line. CMS has put together a grouping tool to help agencies understand how the proposed payment grouping parameters would impact payments.

To use it, your agency will need to input several months of data from patients under the current system and see how much of a difference the new payment model would make on payments received.

Click here to access the Excel file available on the CMS web site at http://go.cms.gov/2f12QpC.

How the new HHGM would affect home health agencies

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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

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

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

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

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

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

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

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

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

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

How many of the reviewers are clinicians?

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

Are they credentialed in home health and hospice specific coding?

Are the reviewers located in this country or abroad?

Are they HIPAA trained?

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

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

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

The HHS Who’s Coding You Challenge

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

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

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

Other OIG concerns

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

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

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

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

Here is a link to review the OIG work plan.

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.


   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
– 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



   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.


   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:


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.

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

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

We can help!

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