A review of COVID-19 updates for home care and hospice agencies, created/originally published on April 11, 2020. With the rapid advance and response to this novel coronavirus, be sure to check this blog often for new information.
QIRT is considered an essential business because we partner with frontline agencies. More importantly, we are proud supporters of frontline workers/ first responders and other healthcare agencies during this unprecedented time. There have been many changes both to our lives and to the agencies that we work with. The Center for Medicare and Medicaid Services (CMS) and the National Association for Homecare and Hospice (NAHC) have been working tirelessly to make changes that keep agencies up-to-date and empower them to continue to care for their patients during the pandemic. CMS has done a great deal of work in a very short period of time, and fortunately, many items that the industry has been advocating for well over 10 years are coming to fruition now.
NAHC has been working tirelessly to unwrap the new COVID-19 regulations and requirements. Those that pertain to our industry specifically:
Home health agencies are now allowed to use telehealth to perform visits. CMS is looking at the payment for these visits, although currently they are not allowed to set payment rates for non-in-home visits. It is likely this will be further discussed. Telehealth visits are now allowed across the board but have to be audio and telephonic (Facetime and Skype are allowed). Agencies are utilizing telehealth and telephonic only calls for care management to carry them through this crisis.
How does telehealth work in practice? The doctor must order the telehealth; it must be MD approved, it cannot be the agency’s decision. The prescription has to be in the plan of care, including the reason why the telehealth visit will help. This will help reduce the amount of contact in the in-home setting. We have heard from agencies reporting patients refusing services because they are afraid of catching COVID-19 from workers. There have been a lot of refusals out there because patients do not want visitors in the home.
What about LUPAs?
In order to be paid for a full encounter, agencies must meet the minimum LUPA threshold with in-person visits. The F2F requirement may be a telehealth visit. This is a huge victory for home care, one that our QIRT experts and many others have been advocating for years.
Homebound Status Requirement
Another item we’ve been advocating for years is a relaxation of the requirement for homebound status. Thankfully, the ease in regulation at this moment in time also offers relief for agencies currently on the frontlines. To determine homebound status, you must have a face-to-face with the beneficiary. But for COVID-19, beneficiary, homebound standards can now include patients with a confirmed or suspected COVID-19 diagnosis in the definition of “homebound.” It is contraindicated for the beneficiary to go out of the home due to COVID so they are confined to the home. Now patients with confirmed or suspected COVID-19 diagnoses can immediately qualify for and receive in-home health services under the Medicare home health benefit. CMS will reimburse HHAs if they do COVID testing on their patients; it will be a reimbursable visit. Individuals under “self-quarantine” are not currently covered under this expansion.
The big picture is that health practitioners will now be allowed to order home health care. Nurse practitioners (NPs), physician assistants (PAs), and critical nurse specialists (CNSs). Usually, only physicians were allowed to order this. Keep in mind, this does vary from state to state, so agencies must pay attention to their state regulations. The previously mentioned practitioners can also do research now, in a change of regulations.
OASIS completion and submission standards have been changed. The rule to do an initial assessment was 24 hours with the completion of the comprehensive assessment (OASIS) in 5 days and submission to the repository of the OASIS within 30 days.
At the present time, the initial assessment is 48 hours with the comprehensive assessment by 30 days and the timing submission is now not set for the duration of the COVID-19 emergency rule. The initial assessment can be done remotely or in person. The comprehensive assessment is done in person. However, the rules for payment of the final claim remain intact, so the agency must have a F2F, signed orders, and the OASIS must be in the repository prior to the final claim being sent.
Home health aide supervisions in person are suspended. CMS requests that they are done remotely and documented as such, but the requirement for the orientation in-person visit and the 14-day supervision visit for the home health aide is suspended for the duration. Remember you can use telehealth to do the face-to-face and also to sign orders. F2F are done on hospice patients at the 3rd recertification for the hospice benefit (180 days) and then every recertification period (60 days) after that. These assessments should be through audio and video with the healthcare provider. The hospice volunteer requirement has been waived.
We are relieved by this relaxation of regulations that had been onerous to start with. CMS has done a great deal of work in a very short period of time, and fortunately, many items that the industry has been advocating for well over 10 years are coming to fruition now. It will be interesting to see the lay of the land as we move forward after this crisis – will innovations and new regulations be rolled back? Only time will tell.
In the meantime, we will continue to support our agency partners, care for our own staff, and follow social distancing guidelines. The best way to get ahead of this is to work together… although physically apart.
There are multiple resources that home health agencies can draw upon to support their staff and patients. The National Association for Homecare and Hospice (NAHC) and most regional/state associations are working diligently to support agencies with up-to-date information. Additionally, CMS has released COVID-19 guidelines available for review here:
QIRT experts have created a COVID-19 Preparedness guideline/addendum for your reference. Feel free to contact us for more information.
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