Annette Lee, RN, MS, COS-C from Provider Insights, Inc. has provided a summary of the information released by CMS related to COVID-19. Read the full summary below.
What a whirlwind we have all been through in the last couple of weeks. There has been a LOT of information in the last 10 days – changes hourly sometimes! I wanted to give you an update each Monday morning to filter through the info – provide you the facts and tools you need -and clear up any “myths” floating around out there from the all-too fast and furious news cycle for our industry. So, this is “Issue #1-2020”. I have attached the official CMS publications for HH and Hospice along with some additional tools from our National Associations.
OK, first off – things that affect both HH and Hospice:
- There has been a “National State of Emergency” declared – has your agency enacted your emergency plan? Have you reviewed your policy (example attached) for pandemic emergencies? See attachment #1 for a checklist to guide your preparation.
- Routine state COP surveys postponed at this time – Only immediate jeopardy or infection control issues are current need surveys.
- Providers can practice/provide care in neighboring states without license in that state.
I have been asked “Do we have to go see patients – we are on lock down?” “Are PT visits or aide visits ‘essential’?” “Should we go less often?”
Here’s the fact: Healthcare, including Home Health and Hospice are “Essential services”. So, even if your community is under local rules to stay at home – we are exempt from that. You do NOT want to say too loudly that our visits are not “necessary” or someone may ask why in the world we have been doing these visits and getting paid for these visits in the first place! So, yes, we will visit our patients. Yes, even therapies, or aides, or chaplains (hospice) or social workers. Unless you feel you can meet your goals over the phone or through remote technology – then go ahead and reduce your risk, and do that – document it as a communication note. The only service that gets to put that “visit” on the bill is a social worker under hospice. This allowance for “telephone time” has been in place for some time. Remember that our patient populations are at far more risk than most of us as the healthcare workers – so wearing a mask if you are in an area where there is community spread is important for you to protect the patients and loved ones that are in their homes!
It may be appropriate to reduce risk of exposure to the patient by investigating if less visits can be performed than what was originally ordered. Think about how family may be more motivated to learn the procedure, or you may set up medications for a longer period of time- or the patient may request a bath weekly instead of 2-3 times per week. A safe, methodical reduction in visits that won’t harm the patient is a great plan- but ensure you obtain orders for the reduction, communicate with the patient/family and if home health, provide the HHCCN.
I have heard that many ALFs are not letting HH or hospice staff into their buildings, and nursing facilities (who are under a NO visitor rule from CMS, from which we are exempt) are refusing to let hospice staff visit their patients. Here’s the fact: Assisted livings/group homes, etc are not under CMS jurisdiction – and can make up their own rules. We may not be able to continue to serve these patients under home health. I encourage you to show the ALF the language from CMS to nursing homes that states no visitors – except healthcare workers… but at the end of the day, it is their call.
What should we do? Home Health – place the patient on hold if unable to visit. Provide as much support as possible to the patient and family by phone. They certainly could be very upset that your team can no longer visit. Communicate the plan to “hold” services due to the facility request with the patient, responsible parties, and physician(s). If this hold continues through the end of the certification, (or end of the following month- April) for hospice, then you may be forced to discharge. I have attached an NHPCO tool for your reference regarding hospice in nursing facilities during COVID-19.
The 1135 waiver specifically cited some rules that are relaxed/waived. The one that really got our attention is Telehealth. Telehealth is a current Medicare benefit for patients who live in very rural areas where there is a lack of physicians/NPPs in their area – so the patient could go to a designated site in their community (clinici) and “see” their provider (MD/DO/NP/PA) through a two-way telehealth visit. The provider was able to bill these visits, under this circumstance. This wavier allows the “site” where the visit originates from now to be anywhere – even a patient home – not just this rural pre-approved site!
What does this mean? If you have capability to do Facetime, or Viber or many other two-way communication apps – you have the capability to facilitate a “visit” with the patient to a physician or NP/PA! This may be used in a palliative care patient, for whom you are billing the provider’s visit, or, it could be used by home health to help facilitate a “Face to Face” visit with the patient’s physician, so the patient can qualify for home health, and not be put at risk, by going to the physician’s clinic during this emergency. The physician must now document the visit, and can bill it. The home health will request that visit documentation to ensure compliance with eligibility for the Medicare or Medicaid benefit.
Unfortunately, CMS has stated that the telehealth waiver can NOT be used for the HOSPICE Face to Face needed prior to the 60-day benefit periods. I was in hopes that was about to change today, as the Senate was voting on a bill that would allow this – but the bill did not pass at this time. STAY TUNED hospices – It does appear it is only a matter of time.
The “myth” floating around is that our agency visits can be done by telehealth. This is not considered a visit for home health, nor hospice. I encourage us to maximize our remote communications and support for each of our patients, and review our current POC to see if we can fortify it in other ways, in attempt to limit exposures – but please note telehealth or telephonic communications are NOT “visits”, nor did this waiver allow for this to be viewed as a visit. Agencies CAN capture these costs in their cost reports as an expense. For any of you that have IT departments stating you can’t do this due to HIPAA, please note the OCR took care of this – and attached is also the document in which the OCR stated they would waive any HIPAA concerns regarding communications for telehealth visits during this emergency.
CMS also made a couple of allowances through the 1135 waiver specifically for home health:
- Lifted the OASIS submission timeframe
- Extended the time that is allowed prior to RAPs auto-canceling. (effectively allowing the HHA to maintain that 20% payment longer, until the 30 day claim can get sent, even if a delay).
Please note that things change daily. NAHC will be hosting a weekly townhall for both HH and Hospices every Wednesday through at least the end of April, and also on Friday, 3/27. All fees have been waived, even if you are not a member.
NHPCO is hosting a free COVID update webinar (hoping for more updates from Congress by then!) this Wednesday, right after the NAHC update.
Lastly, we all are acutely aware of the effects of this virus on patients like ours. The last attachment is a guide to assist you in discussing with your patients these risks and outcomes- and the need to determine if a hospitalization is the right course for them. A very difficult discussion, but one that must be had with home health and hospice patients to ensure we not only acknowledge their wishes, but also to openly communicate the facts, and this not only impacts our patients, but our entire community.
More updates to come next monday – if not before!
Annette Lee is a valued member of the home health and hospice industry with many years of experience. She is a featured speaker at the Insight 2020 conference to be held August 16-19 in Nashville. She has summarized the plethora of information that has been coming from CMS in the last few weeks and provided the sources so that everyone can have those readily available. I am also honored to call her a friend.Lisa Selman-Holman
- COVID-19 Homecare & Hospice Checklist
- Nursing Home Guidance
- Pandemic Infectious Disease Policy
- FAQs on Telehealth & HIPAA
- General Provider Telehealth & Telemedicine Tool Kit
- COVID-19 Shared Decision0-Making Tool Kit
All the information presented above was provided by Annette Lee at Provider Insights, Inc.