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Important COVID-19 Updates for Home Health and Hospice Providers

April 06, 2020
Compliance By Patty Klinefelter, Director

During the COVID-19 pandemic, we have all been inundated with emails and a ton of information. The following serves as key home health and hospice information with relevant links. LW Consulting, Inc. hopes this summary of information will assist your organization in your daily operations.

 

COVID_19_Home_Health_Updates


CARES Act

President Trump signed the $2 trillion stimulus package which includes multiple home health provisions:

  • Allows non-physicians to certify home health services. 
  • Permits use of telehealth for hospice face-to-face encounters.
  • Encourages the use of telehealth in home health care consistent with the plan of care and does not replace needed in-person visits as ordered on the plan of care. Currently, Medicare does not provide reimbursement for the use of such tools.
  • Suspends the 2% Medicare sequestration through 2020, effectively boosting reimbursement rates for providers during an eight-month period.
  • Creates a $100 billion health care fund for recovering COVID-19 cost. Agencies will need to develop a tracking system for all COVID-19 related expenses.
  • Increases Medicare reimbursement to providers for taking care of COVID-19 patients.


CMS Flexibilities to Fight COVID-19

On March 30, 2020, the Trump Administration issued additional temporary regulatory waivers to allow more flexibility to home health agencies to respond to the 2019 COVID-19 pandemic.

The effective date of the new waivers is March 1, 2020 through the end of the emergency declaration. 

Sources:
https://www.cms.gov/files/document/covid-home-health-agencies.pdf

MLN Matters Number: SE20011 Revised Article Release Date: March 20, 2020 https://www.cms.gov/files/document/se20011.pdf


Home Health Agencies (HHAs)

  • Homebound:
    • A beneficiary is considered homebound when their physician advises them not to leave the home because of a confirmed or suspected COVID-19 diagnosis or if the patient has a condition that makes them more susceptible to contract COVID-19. As a result, if a beneficiary is homebound due to COVID-19 and needs skilled services, an HHA can provide those services under the Medicare Home Health benefit.
  • To ensure the correct processing of home health emergency related claims, Medicare Administrative Contractors (MACs) are allowed to extend the auto-cancellation date of Requests for Anticipated Payment (RAPs).
  • The Centers for Medicare & Medicaid Services (CMS) is providing relief to HHAs on the timeframes related to Outcome and Assessment Information Set  (OASIS) transmission through the following actions below:
    • Extending the 5-day completion requirement for the comprehensive assessment to 30 days.
    • Waiving the 30-day OASIS submission requirement. Delayed submission is permitted until the end of the declared emergency.
    • Initial Assessments:
      • CMS is waiving the requirements at 42 CFR §484.55(a) to allow HHAs to perform Medicare-covered initial assessments and determine patients’ homebound status remotely or by record review. This will allow patients to be cared for in the best environment for them while supporting infection control and reducing impact on acute care and long-term care facilities. Doing so maximizes coverage if there are limited physicians and advanced practice clinicians and allows those clinicians to focus on caring for patients with the greatest acuity.
    • Waiver of onsite visits for HHA Aide Supervision:
      • CMS is waiving the requirements at 42 CFR §484.80(h), which require a nurse to conduct an onsite visit every two weeks. This would include waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan, as this may not be physically possible for a period of time. This waiver is also temporarily suspending the 2-week aide supervision by a registered nurse for HHAs requirement at §484.80(h)(1), but virtual supervision is encouraged during the period of the waiver.


Hospice

  • Waiver of Requirement for Hospices to Use Volunteers:
    • CMS is waiving the requirement at 42 CFR §418.78(e) that hospices are required to use volunteers (including at least 5% of patient care hours). It is anticipated that hospice volunteer availability and use will be reduced related to COVID-19 surge and potential quarantine.
  • Comprehensive Assessments:
    • CMS is waiving certain requirements at 42 CFR §418.54 related to updating comprehensive assessments of patients. This waiver applies the timeframes for updates to the comprehensive assessment found at §418.54(d). Hospices must continue to complete the required assessments and updates, however, the timeframes for updating the assessment may be extended from 15 to 21 days.
  • Waiver of Non-Core Services:
    • CMS is waiving the requirement for hospices to provide certain non-core hospice services during the national emergency, including the requirements at 42 CFR §418.72 for physical therapy, occupational therapy, and speech-language pathology.
  • Waived Onsite Visits for Hospice Aide Supervision:
    • CMS is waiving the requirements at 42 CFR §418.76(h), which require a nurse to conduct an onsite supervisory visit every two weeks. This would include waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan, as this may not be physically possible for a period of time.


OIG Message on Minimizing Burdens on Providers

  • On March 30, 2020, the Office of Inspector General (OIG) released a message on minimizing burdens on providers during the COVID-19 pandemic. During this time, OIG will attempt to minimize provider burden and grant flexibility when possible. 
  • Health care organizations that need extensions of OIG deadlines, such as to produce data for an OIG review or to comply with a Corporate Integrity Agreement, are encouraged to ask their OIG contact. OIG will work with organizations on a reasonable solution.
  • For any conduct during this emergency that may be subject to OIG administrative enforcement, OIG will carefully consider the context and intent of the parties when assessing whether to proceed with any enforcement action. 
  • OIG also encourages electronic submissions of any materials that would ordinarily be mailed, as mail service has been temporarily suspended. There is a dedicated COVID-19 portal accessible from the OIG homepage with up to date information about operations, contact information, and COVID-related work.


Medicare Quality Reporting

In response to COVID-19, CMS announced on March 22, 2020 relief for the clinicians, providers, and facilities participating in Medicare quality reporting programs including hospice and home health that data from January 1, 2020 through June 30, 2020 (Q1-Q2) does not need to be submitted to CMS for purposes of complying with quality reporting program requirements. Home Health and Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey data from January 1, 2020 through September 30, 2020 (Q1-Q3) does not need to be submitted to CMS.

For those programs with data submission deadlines in April 2020 and May 2020, submission of those data will be optional and based on the facility’s choice to report. In addition, no data reflecting services provided January 1, 2020 through June 30, 2020 will be used in CMS’ calculations for the Medicare quality reporting and value-based purchasing programs. This is being done to reduce the data collection and reporting burden on providers responding to the COVID-19 pandemic.

CMS recognizes that quality measure data collection and reporting for services furnished during this time period may not be reflective of their true level of performance on measures such as cost, readmissions and patient experience during this time of emergency and seeks to hold organizations harmless for not submitting data during this period.


CMS Issues Face-to-Face Guidance

Under the expansion of telehealth, in accordance with the 1135 waiver, beneficiaries are able to use telehealth technologies with their doctors and practitioners from home (or other originating site) for the face-to-face encounter to qualify for Medicare home health care.

CMS issued guidance permitting physicians to conduct face-to-face encounters for home health via telehealth during the COVID-19 pandemic for the expansion of telehealth under the 1135 waiver.


Draft OASIS E

The draft OASIS-E All Items Instrument is now available in the Downloads Section of the OASIS Data Sets web page. OASIS-E will be effective January 01, 2021. Please note the instrument is not yet final. Office of Management and Budget (OMB) approval is required and expected later this year.


ICD 10 Coding

The Centers for Disease Control and Prevention’s (CDC) National Center for Health Statistics (NCHS) assigned a new diagnosis code U07.1 for COVID-19.

Because of the new code, an updated version of the ICD-10 MS-DRG GROUPER software package, effective with discharges on and after April 1, 2020, is available on the CMS’ website.

According to CMS, the updated GROUPER software package replaces the GROUPER software package V37.1 that was developed in response to the new ICD-10-CM diagnosis code U07.0, Vaping-related disorder.

 

LW Consulting, Inc. extends a thank you to the healthcare providers and agencies for the everyday COVID-19 battles they are fighting.
If you need any support during these trying times, please reach out and contact Patty Klinefelter at 540-686-1311 or email PKlinefelter@LW-Consulting.com.

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