Annette Lee, RN, MS, COS-C from Provider Insights, Inc. has provided more updates on the information released by CMS related to COVID-19. Read the full summary below.
Well, within 24 hours from my last email this week, we had more news and clarifications, and today, even better and bigger changes will provide us with a little relief!! I know you are busy – so, I am just providing the “cliff notes” here and attaching supportive documentation.
QUALITY REPORTING GRACE
We knew that the timeliness of OASIS submission was one of the waivers cited by CMS, last week, but we also had clarification on Monday that CMS was going to give us all a “pass” on the Home Health and Hospice Quality Reporting programs. What does this really mean?
- It means that CMS will not be using our OASIS or HIS for any quality calculations from January 1 – June 30th. They recognized that the pandemic not only straps our agencies for resources, but also limits and impacts some of our patient’s outcomes. If the data from HIS or OASIS is submitted late, during this time, there will be no penalty. I have requested formal guidance from CMS if we may completely waive collecting this data at this time under the 1135 waiver, along with other state and national associations. I will keep you updated.
- CAHPS data for both Home Health and Hospice will be excused through September 30th, 2020! That is right – no CAHPS data needed during this time of crisis – This spurs me to ask our vendors to put our service (and our bill!) on hold these next six months!
The Coronavirus Aide Relief and Economic Security Act (CARES) was signed into law, providing 2 trillion dollars of different reliefs for the economic turmoil caused by COVID-19. Buried within that bill were a few wonderful reliefs for home health and hospice:
2% Raise from May 1st – December 31st, 2020 for all HH and Hospice Medicare services
- The 2% sequestration reduction we have had for our HH and Hospice Medicare claims will be lifted beginning May 1st- December 31st at this time. This could be extended, but for now, we are looking forward to the small change in May. This unfortunately does then extend the sequestration until 2030 (from 2029).
Home Health and HOSPICE FTF by per Telehealth allowed
- Last week we learned that the Telehealth visits, which used to be covered only when the patient lived in a designated rural area, at a designated site, now were allowed from any originating site. This could even be in the patient’s home! What a game changer! These visits were available under Part B, by a physician or NP in a palliative care program, or a physician or non-physician provider under Part B, which could then be used to qualify a patient for the Home Health benefit. These allowances are DURING the EMERGENCY period.
- Today HOSPICE joins this benefit with the passage of CARES, and our hospice physicians and NPs can now provide the FTF encounter for recertications by telehealth, DURING the EMERGENCY period.
- What does this mean? Any front-facing, two way device with audio and video can be used. This could be an iPhone with Facetime, or a smart phone with Google, or Viber. The provider must be able to see the patient and visa versa.
- Concerned about HIPAA? Don’t worry- the Office of Civil Rights released guidance clearing this during this emergency period and stated there would be no penalties for these security risks during this time of emergency.
COMING SOON!! HOME HEALTH – Physician Assistants and Nurse Practitioners will be able to ORDER and CERTIFY for HH services!
- The CARES Act updated the SSA which defined who could certify and direct a plan of care for home health. The Social Security Act is the LAW that has always mandated only physicians could order home health
- This update will not be enacted until CMS can update the regulation. Regulations are under the law. So, 42CFR424 will need to be updated, along with the “G-tag” standards, the Medicare Benefit Policy Manual (chapter 7) and the Claims Processing Manual. Once CMS has a chance to update the regulation and provide guidance, they will direct home health agencies on the date this is to be enacted. The CARES Act mandated it needed to be within six months from today. (Sept 27, 2020)
A question that keeps coming up – can our agency visits (nurse, social worker, etc) be done by telehealth? From a regulatory perspective, we can always communicate with patients in this way – but they are not defined as “visits” under HH or Hospice (except, there is a revenue code to bill MSW phone time when related to the POC). So, no, this change has not been made by Medicare. But, what CMS does say (even in the CARES Act) is that they encourage us to use this technology to enhance our care, to keep us and our patients safe. So, please do review each of your patient’s care plans – and look to see what takes an in-person, in the home visit, or what may be done off-site and still offer the care and support of that discipline. Talk with the physician. Alter your plans of care accordingly with the physician. Please stay safe out there – don’t hesitate to get in touch if you have questions, or if I can be of assistance.
- Medicare Telehealth Frequently Asked Questions
- HIPAA Notification of Enforcement Discretion for Telehealth
- COVID-19 Home Care and Hospice Checklist
- Patient Guide for COVID-19
- General Provider Telehealth and Telemedicine Tool Kit
- Pandemic Infectious Disease Policy
- FAQs on Telehealth and HIPAA during COVID-19
- Home Health Orders NP PA, 2020
All the information presented above was provided by Annette Lee at Provider Insights, Inc.
To view the first update of “Changes in our world of Home Health & Hospice related to COVID-19” from 3/23, click here.