Home Health Regulatory Update - Amazon S3 · PDF file• Removed the measure for Drug...

12/20/2017

Home Health Regulatory Update: CY2018 Final Rule and Upcoming CoP Implementation (c)HEALTHCAREfirst 12/2017 1

Copyright © 2017 HEALTHCAREfirst. All rights reserved.

Home Health Regulatory UpdateDecember 2017

Presented by:Deanna LoftusDirector of Regulatory ComplianceMary St. Pierre RN, BSN, MGAFormer VP of Regulatory Affairs for the NAHC


Before We Get Started

• Audio is through computer speakers or select “Phone” on Audio Pane to call in. All attendees are muted.

• You can ask questions via the GoToWebinar Question Pane throughout the presentation.

• Handout can be found on the “Handout” pane in the GotoWebinarControl Panel.

• On‐demand video will be made available following the webinar.

12/20/2017



About HEALTHCAREfirst

• Industry leader in Web‐based EHR software, coding & billing services, CAHPS survey administration, and advanced analytics for home health and hospice:

– Founded in 1992

– Headquartered in Springfield, MO with additional office in Louisville, KY

– One of the fastest growing providers of our kind

– More than 4,000 home health and hospice agencies nationwide

• We enable our customers to:– Make timely and accurate decisions for excellent patient care

– Adapt quickly to changing requirements and needs

– Automate agency functions quickly and with high value.


SOFTWARE• Web‐based Agency Management Software for home health & hospice agencies

• DDE Connectivity

• All Payer Eligibility Verification

• Physician Portal

• OASIS Scrubber

SERVICES• Coding

• OASIS Review

• Billing

• CMS Submission of Hospice Item Set Data

ADVANCED ANALYTICS• Executive, Clinical and Financial KPIs

• Market insights to grow referrals

• Robust QAPI management & benchmarking

• Hospice CAHPS & Home Health CAHPS

EHR Software and Beyond

12/20/2017



• Strengthen Profitability

• Ensure Compliance

• Improve Quality

Total Solutions Provider


Partnering for Success

• The right EHR can resolve requirement needs and direct focus to the patient

• CAREpliance™ technology

is built for care and built

for compliance, yielding:

faster reimbursement

improved outcomes

higher satisfaction rates

12/20/2017



Agenda

• 2018 HH PPS Final Rule

– Changes Effective January 1, 2018

• Update Payment Rates

• Re‐calibration of Case Mix Weights

• HHVBP

– Changes Effective January 1, 2019

• Oasis C2

• HHQRP

• Upcoming updates, mandates and important reminders

– Home Health Conditions of Participation


2018 HH PPS Final Rule

• Final Rule:– https://www.gpo.gov/fdsys/pkg/FR‐2017‐11‐07/pdf/2017‐23935.pdf

• Fact Sheet:– https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact‐

sheets/2017‐Fact‐Sheet‐items/2017‐11‐01‐2.html

• Wage Index and Case Mix Weights:– https://www.cms.gov/Medicare/Medicare‐Fee‐for‐Service‐

Payment/HomeHealthPPS/Home‐Health‐Prospective‐Payment‐System‐Regulations‐and‐Notices‐Items/CMS‐1672‐F.html

12/20/2017



2017 vs. 2018 Payment Rates

• Effective for episodes ending on or after January 1, 2018

• Medicare payments estimated to be reduced by 0.4% or $80 million overall.

• 3 percent add‐on for services provided in rural areas has been eliminated

2017 Base Rate / Rural Base Rate 2018 Base Rate (Final)

$2,989.97/ $3,019.58 $3,039.64 / No Rural Add-On


2017 vs. 2018 Discipline Rates

Discipline 2017 Non-Rural / Rural 2018 (Final)

HHA $64.23/ $66.18 $64.94/ No Rural Add-On

MSW $227.36 / $234.18 $229.86 / No Rural Add-On

OT $156.11 / $160.79 $157.83 / No Rural Add-On

PT $155.05 / $159.70 $156.76 / No Rural Add-On

SN $141.84 / $146.10 $143.40 / No Rural Add-On

SLP $168.52 / $173.58 $170.38 / No Rural Add-On

*Note a 2% reduction to these rates when not submitting quality data

12/20/2017



2017 vs. 2018 Non‐ Routine Supply Rates

SeverityLevel

2017 Non-Rural / Rural 2018 (Final)

1 $14.16 / $14.59 $14.31 / No Rural Add-On

2 $51.15 / $52.68 $51.66 / No Rural Add-On

3 $140.24 / $144.46 $141.65 / No Rural Add-On

4 $208.35 / $214.62 $210.45 / No Rural Add-On

5 $321.29/ $330.96 $324.53/ No Rural Add-On

6 $552.58 / $569.21 $558.16 / No Rural Add-On



LUPA Add‐On Rates

LUPA

SN – 1.8451PT – 1.6700SLP – 1.6266

http://www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html?redirect=/center/hha.asp


12/20/2017



Outlier Payment and FDL Ratio

• No updates to last years cost per visit approach implementation, based on 15‐minute service units.

• No changes to the cap on the amount of time per day that is counted toward the estimation of an episodes costs for outlier calculations.

– CMS will continue to limit the amount of time per day (summed across the six disciplines of care) to 8 hours (32 units) per day when estimating the cost of an episode for outlier calculation purposes.

• Loss ratio to remain at 80%

• The fixed‐dollar loss ratio that is used to calculate outlier payments will remain at 0.55.


Value‐Based Purchasing Updates

• Removed the measure for Drug Education on all Medications

• Changed the minimum number used for surveys from 20 to 40

12/20/2017



HHQRP 2019/2020 Updates

• CMS finalized several HHQRP items that will begin in 2019. They did not finalize the standardized assessment item for Cognitive Function and Mental Status; Special Services, Treatments, and Interventions; and Impairments.

• HEALTHCAREfirst will host a webinar in 2018, closer to the implementation date to review the 2019/2020 changes in depth.


HHQRP 2019 Changes at a Glance

• 235 data elements will be removed from 33 current OASIS items, effective with all HHA assessments on or after January 1, 2019.

• CMS finalized several procedural requirements, including a process for requesting reconsideration of determinations regarding compliance as well as policies for requesting exceptions and extensions of reporting timeframes.

12/20/2017



HHQRP 2020 Changes at a Glance

• Beginning with the CY 2020, 3 new measures will be adopted that meet the requirements of the IMPACT Act, that are assessment‐based and calculated using OASIS data: – Changes in Skin Integrity Post‐Acute Care: Pressure Ulcer/Injury;

– Application of percent of residents experiencing one or more falls with major injury (National Quality Forum NQF # 0674); and

– Application of percent of Long‐Term Care hospital patients with an admission and discharge functional assessment and a Care Plan that addresses function (NQF #2631).


What’s On the Horizon

• SSN to MBI Transition

• Conditions of Participation

12/20/2017



Social Security Number Removal Initiative (SSNRI)

• The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015) requires CMS to remove Social Security Numbers from all Medicare cards by April 2019.

• A new Medicare Beneficiary Identifier (MBI) will replace the SSN‐based Health Insurance Claim Number (HICN) on the new Medicare cards for Medicare transactions like billing, eligibility status, and claim FISS/DDE

• New Cards will be mailed beginning in April of 2018

• Transition period will begin no earlier than April 1 of 2018 and run through December 31, 2019.

https://www.cms.gov/medicare/ssnri/index.html


Social Security Number Removal Initiative (SSNRI) cont.

• During the transition period, providers will be able to use either the SSN or the MBI to exchange data with CMS.

• The MBI will be: – Clearly different than the HICN and RRB number

– Be 11‐characters in length

– Be made up only of numbers and uppercase letters (no special characters)

– Be randomly generated. (The characters are "non‐intelligent," which means they don't have any hidden or special meaning.)

12/20/2017



Home Health Conditions of Participation

• Final Rule Revised – Effective date January 13, 2018

– Exception: QAPI data driven improvement projects July 13, 2018– https://www.federalregister.gov/documents/2017/01/13/2017‐00283/medicare‐and‐medicaid‐

program‐conditions‐of‐particiation‐for‐home‐health‐agencies.

• DRAFT Interpretive Guidelines– http://report.nahc.org/wp‐content/uploads/2017/10/3819‐F‐HomeHealthAgency‐CoPs_IGs.pdf


Home Health Conditions of Participation

• PARENT– Removed Subunit

– Survey and Cert Letter 18‐03 [PDF, 187KB]

• BRANCH OFFICE – Removed “sufficiently close.” Added parent home health agency must provide supervision and

administrative control of any branch office.

• HHA Action– Make Subunits status determination– Ensure administrator and governing body requirements met– Complete SA and MAC requirements to convert Subunits

– Review parent/branch relationship

– Ensure policies and processes to exercise supervision and control of parent over branch offices– Educate personnel on parent supervision and control of Branch

12/20/2017



42 CFR §484.2: Definitions

• REPRESENTATIVE– Patient’s legal representative, such as a guardian, who makes healthcare decisions on the

patient’s behalf, or a patient‐selected representative who participates in making decisions related to the patient’s care or well‐being, including but not limited to, a family member or an advocate for the patient. The patient determines the role of the representative, to the extent possible

• HHA Action: By January 2018 – Proper patient representative/caregiver identification

– Develop policies and procedures to comply with new requirements

– Educate personnel on responsibilities related to representatives/caregivers


42 CFR §484.50: Patient Rights

• Standards: – Rights of the Patient; Notice and Exercise of Rights; Transfer and Discharge Requirements

– Accessibility

– Investigation of complaints

• HHA Action: By January 2018 – Create/procure new patient rights forms

– Deliver new rights forms to existing patients

– Ensure inclusion of:• All rights

• Transfer and Discharge policies

• Names and phone number of State/Federal funded agencies

• Name and contact information of agency administrator

12/20/2017



42 CFR §484.50: Patient Rights

• HHA Action: By January 2018

– Review current policies and procedures

– Compare federal, state, accreditation requirements

– Write/implement policies and procedures that:

• Address all rights

• Address delivery of rights, including timelines

• Identify uses of cultural and linguistic services, interpreter services, voice recognition, common translations, texts

• Identify communication devices, services, materials,

• Define complaint investigation procedures

• Educate staff


IG Concerns

• IG Statements– Documents must be “understandable”

– All agency staff should be trained to identify patients with any language barriers …trained in effective communication

– The HHA should make all reasonable attempts to respect the preferences of the patient regarding the services that will be delivered such as the HHA visit schedule should be at the convenience of the patient rather than of the agency personnel

12/20/2017



42 CFR §484.55: Comprehensive Assessment

• Standard: Additions to content of Comprehensive Assessment– Psychosocial and Cognitive status

– Patient’s strengths, goals, and care preferences

– Progress toward achievement of the goals identified by:• Patient

• Measurable outcomes identified by the HHA

– The patient's continuing need for home care

– Primary caregiver(s), if any, and other available supports• Willingness and ability to provide care, and

• Availability and schedules

– The patient’s representative (if any)

– Emergency preparedness screening



• HHA Action: By January 2018 – Review current comprehensive assessment

– Review state and accreditation requirements

– Communicate/plan with software vendor, forms creator

– Integrate items into assessment

– Revise assessment policies and protocols

• Focus on patient preferences, strengths, caregiver/representative involvement

– Consider use of caregiver screening tools

– Educate employees/contractors on assessment focus, added items, strategies, documentation requirements

12/20/2017




• Standard: Update of Comprehensive Assessment

– Within 48 hours of discharge or on the physician‐ordered resumption date


– Review and amend resumption of care assessment policy

– Identify “physician‐ordered date”

– Educate employees/contractors on changes to timing


IG Concerns

• IG Statements– The subsequent 60‐day period would then be measured from the

completion date of the last update

– Medication review by therapists, the therapist submits a list of the medications, which he/she collects during the comprehensive assessment to a HHA nurse for review

12/20/2017



42 CFR §484.60: Care Planning, Coordination, and Quality of Care

• Standard: Additions to content each patient must receive a Plan of Care that includes:– Psychosocial and Cognitive status

– A description of the patient’s risk for emergency department visits and hospital re‐admission

– Patient‐specific interventions to address the underlying risk factors

– Patient and caregiver education and training to facilitate timely discharge

– Patient‐specific interventions and education

– Measurable outcomes and goals identified by the HHA and the patient

– Information related to any advanced directives

– Any additional items the HHA or physician may choose to include



• HHA Action: By January 2018 – Review current Plan of Care

– Review state and accreditation requirements

– Identify new information and integrate new items, protocols• Advance directives

• Risk for hospitalization and interventions

• Patient/caregiver education

• Patient goals

– Revise care planning and documentation policies and protocols

– Focus on patient preferences, strengths, caregiver/representative involvement

– Educate employees/contractors on assessment focus, added items, strategies, documentation requirements

12/20/2017




• Standard: Review and Revision of Plan of Care and Coordination– Revisions to the Plan of Care must be communicated to:

• Patient, representative (if any), caregiver, and all physicians issuing orders

– Revisions to patient’s discharge must be communicated to patient, representative, caregiver, all physicians issuing orders, patient’s primary care practitioner or other responsible after discharge

– Orders must be integrated from all physicians into the Plan of Care

– Physician(s) must be promptly alerted to change suggesting need change in Plan of Care

– Plan of Care/revisions must reflect patient’s current condition, progress towards goals

– Verbal orders must be

• Accepted by authorized personnel

• Documented, signed, dated, timed (time received)

– 409.43 put in writing and signed by RN or qualified therapist




– Establish interdisciplinary Plan of Care with integration of all orders

– Create processes for identification of the “physician responsible for the Plan of Care” for each patient

– Revise policies and protocols for creation of a “revised Plan of Care” including all verbal orders

– Revise policies and procedures to ensure patient changes/copy of the Plan of Care (and revised Plan of Care) to all ordering physicians with signature by physician responsible for the Plan of Care

– Ensure that all verbal orders are signed, dated, with receipt time

12/20/2017





– Assess adequacy of current practices

– Revise policies and processes for notifying patient/caregiver of changes to Plan of Care as needed

– Develop policies/processes for notifying patient, representative, caregiver, physician(s), and post discharge practitioner of changes to discharge plan

– Educate employees/contractors in Plan of Care regulations/procedures

– Reevaluate processes for ongoing compliance


IG Concerns

• IG Statements– The HHA includes goals for the patients, patient preferences and service schedules frequencies as a

part of the plan of care– The most current written visit schedule for each service is provided to the patient and is consistent

with the most current plan of care– If the HHA misses visits or services…, it must notify the responsible physician…if there is any

potential for clinical impact upon the patient– As these changes are identified there must be evidence (vs. written notice) in the clinical record that

the HHA discussed these changes with the patient, his/her representatives…physician.– Upon admission or upon any change in patient condition, the responsible physician identifies any

other relevant physicians that should be contacted for orders to be included in the HHA plan of care…”

– Once the comprehensive assessment is completed (within 5 days of the initial visit) and the plan of care is approved by the responsible physician, the documents listed in (e) (1‐5) must be provided to the patient and/or their representative

12/20/2017




• Standard: Written information to the patient

– The HHA must provide the patient and caregiver with a copy of written instructions outlining:

• Visit schedule

• Frequency of visits

• Patient medication schedule/instructions: name, dosage, frequency, including medications that will be administered by HHA

• Any treatments, including therapy services.

• Any other pertinent instructions

• Name and contact information of the HHA clinical manager




– Investigate means, tools for creation/delivery of required information

• Start of care

• Changes to Plan of Care, discharge plans

– Develop/revise forms/procedures as needed

– Create, purchase patient educational materials

• Identify procedures for distribution

– Educate employees/contractors

– Revaluate/revise processes as needed

12/20/2017



• Standard: Develop, Implement, Evaluate, and Maintain QAPI Program

– Oversight by governing body to ensure that the program

• Maintain documentary evidence of QAPI program

• Be able to demonstrate its operation to CMS

• Standard: Program Scope

– Identification of appropriate indicators are measurable improvement in all services, include adverse events

– Will improve health outcomes, patient safety, and quality of care

• Standard: Program Data

– The program must utilize quality indicator data (focus on improved outcomes)

– Obtain governing body approval of frequency and detail of data

• Standard: Program Activities

– Based on incidence, relevance, severity

– Lead to correction and improvement

– Can be tracked for sustainability

§484.65 Condition of Participation:Quality Assessment, Performance Improvement


• HHA Action: By January 2018 – Evaluate current quality improvement activities (in compliance, effective)– Analyze patient population, needs, trends, issues– Educate governing body about new requirement, engage in planning– Educate clinicians (employees and contractors) about new requirement, engage

in planning – Identify/create additional data sources

• OBQI reports, OBQM reports, ED and hospital admission rates, CAHPS reports, diagnosis data, infection rates, fall reports, patient demographics, admission and discharge data, survey reports, staff satisfaction, incident reports, complaint logs, length of stay, other

– Review and revise at least annually


12/20/2017




• HHA Action: By July 2018

– Develop and conduct appropriate improvement program activities

• Improved surveillance and new data sources

• Research new/improved care delivery models

• Promotion of consistent delivery of latest clinical practices

• Development of effective care coordination processes

• Patient engagement efforts

• Staff education


§484.70 Condition of Participation: Infection Prevention and Control

• Standard: Prevention– Follow accepted standards of practice to prevent the transmission of infections and

communicable diseases.

• Standard: Control– Maintain a coordinated agency‐wide program

• Surveillance, identification, prevention, control• Investigation of infectious and communicable diseases

– Include in infection control program • Method for identifying infectious and communicable disease problems • Plan for appropriate actions for improvement and disease prevention

• Standard: Education– Provide infection control education to staff, patients, and caregiver(s)

12/20/2017



§484.70 Condition of Participation: Infection Prevention and Control

• HHA Action: By January 2018 – Review current or establish infection control program– Identify data sources – Develop policies and procedures for

• Surveillance• Prevention and control• Investigation

– Create educational programs for employees/contractors (initial and ongoing)• Provide necessary PPE• Monitor staff compliance with prevention measures

– Develop educational information for patients/caregivers (written, demonstration, resources)

• Include standardized educational information in Plan of Care (e.g. handwashing, signs of infection)

• Include standardized educational information in admission packet


IG Concerns

• IG Statements– CMS clinical practice guidelines!!!

• E.g. prohibit mixing of medications

– Reusable medical equipment (e.g., blood glucose meters and other devices such as, blood pressure cuffs, oximeter probes) must be cleaned/disinfected prior to use on another patient and when soiled.

– Each skilled professional discipline attends all in‐service training sessions and programs required by the HHA

12/20/2017



§484.75 Condition of Participation:Skilled Professional Services

• Standard: Responsibilities of Skilled Professionals (RN, PT, SLP, OT‐Employees and Contractors)– Ongoing interdisciplinary assessment of patient– Development and evaluation of the Plan of Care in partnership with the patient,

representative (if any), and caregiver(s)– Providing services ordered by the physician in the Plan of Care; – Patient, caregiver, and family counseling – Patient and caregiver education – Preparing clinical notes – Communication with all physicians involved in the Plan of Care and other health

care practitioners (as appropriate) related to the current plan of care – Participation in the HHA’s QAPI program – Participation in HHA‐sponsored in‐service training


§484.75 Condition of Participation:Skilled Professional Services


– Review job descriptions and contracts

– Ensure that job descriptions include

• Responsibilities in accord with CoP

• Tasks, functions, other responsibilities, scope of authority, relationships, qualifications and skills

– Address with/education employees/contractors on changes

– Consult attorney regarding contract employee status/rights

12/20/2017



IG Concerns

• IG Statement– Specific written instructions for therapy assistants must be based on

treatments prescribed in the plan of care, patient assessments by the skilled professional, and accepted standards of professional practice.


§484.80 Condition of Participation:Home Health Aide Services

• Standard: Home Health Aide Qualifications– Nurse aide training and competency evaluation– Additions: Communication skills, skin care

• Standard: Home Health Aide Training Program and Competency Evaluation

• HHA Action: By January 2018 – Review state, accrediting body requirements– Amend job qualifications– Review and amend agency policies – Identify state registry sources/sites– Consider “aide orientation” to home health– Review training program content– Provide and document training of current aides in new communication and skin condition requirements– Amend job descriptions as necessary– Revise policies, documentation procedures if needed– Contact/advise feeder training programs of changes

12/20/2017




• Standard: Home Health Aide Assignments, Duties

– Assigned by registered nurse or other appropriate skilled professional

– Written patient care instructions prepared by that registered nurse or other appropriate skilled professional (physical therapist, speech‐language pathologist, or occupational therapist)


– Revise policies and procedures to accommodate changes

– Educate nurses and therapists (employee and contracted)



• Standard: Home Health Aide Supervision (Required Content)– Home health aide supervision must ensure that aides furnish care in a safe and

effective manner, including, but not limited to, the following elements:

• Following the patient’s Plan of Care for completion of tasks assigned

• Maintaining an open communication process with patient, representative, caregivers, and family

• Demonstrating competency with assigned tasks

• Complying with infection prevention and control policies and procedures

• Reporting changes in the patient’s condition

• Honoring patient rights

12/20/2017



• Standard: Home Health Aide Supervision

– Supervision by RN or other appropriate skilled professional familiar with the patient,plan of care, and written patient care instructions

– If area of concern noted in aide services

• Supervising individual must make an on‐site visit to location where patient is receiving care

• Observe and assess the aide while performing care

– RN or appropriate skilled professional must

• Make an annual on‐site visit to the location where a patient is receiving care

• Observe and assess each aide while he or she is performing care

– If a deficiency in aide services is verified during an on‐site visit

• HHA must conduct, and the home health aide must complete a competency evaluation





– Revise policies and procedures to accommodate changes

• Flexibility in aide supervision (Start after 1/18)

• Required elements of supervisory visit

• Identification of areas of concern necessitating onsite observation

• Determination of “deficiency” necessitating competency evaluation

• Conduct of supervisory visit/address specific elements

• Documentation of findings

– Educate home health aides, nurses, therapists (employee and contracted) in aide requirements

12/20/2017



IG Concerns

• IG Statements– Each of the tasks above must be observed in its entirety to confirm the

competence of the HHA aide The tasks must not be simulated in any manner and the use of a mannequin is not an acceptable substitute

– RN supervision means that the RN approves the content and attends the presentation to ensure the content is consistent with the HHA’s policies and procedures

– Other individuals “refers to: Physical therapists; Occupational therapists; Speech and language pathologists; Medical social workers, LPN/LVNs; and Nutritionists

– However, it is possible that a skilled therapist may identify the need for home health aide services as discussed in §484.80 (b) (3) in association with a skilled therapy service only. In these cases the skilled therapist may develop the plan for the aide and may perform the supervisory visit


IG Concerns

• IG Statements– Assistance in administering medications in this requirement means

that the HH Aide may take only a passive role in this activity. This assistance is limited to getting water or fluids for the patient to take their medication.

– The home health interdisciplinary team, “which meets together”

12/20/2017



§484.100 Condition of Participation: Compliance Federal, State, Local Laws/Regs

• Standard: Laboratory Services– HHA may not substitute its equipment for a patient’s equipment when

assisting with self‐administered tests.

• HHA Action: By January 2018 – Review and revise current policies as needed

– Identify available resource for procurement of affordable testing devices and supplies by patients.

• Coordinate pre‐discharge provision is possible

– Educate clinicians and patients on policy


§484.102 Condition of Participation: Emergency Preparedness

• Emergency Preparedness Requirements – https://www.gpo.gov/fdsys/pkg/FR‐2016‐09‐16/pdf/2016‐21404.pdf

• Effective November 15, 2016• Implementation date: Compliance by November 15, 2017• Must comply with all applicable federal, state, and local emergency preparedness requirements

– Provider Resources• https://www.healthcarefirst.com/webinars/ Home Health Emergency Preparedness

Requirements: Getting Your Agency Read• https://www.cms.gov/Medicare/Provider‐Enrollment‐

andCertification/SurveyCertEmergPrep/index.htm• https://www.cms.gov/Medicare/Provider‐Enrollment‐and‐

Certification/SurveyCertEmergPrep/Downloads/SandC_EPChecklist_Provider.pdf• https://www.usuhs.edu/ncdmph• https://asprtracie.hhs.gov/technical‐resources/51/Homecare/51

12/20/2017




• Standard: Create, Review and Update Annually– Risk Assessment and Planning

• Develop an emergency plan based on a location specific risk assessment– Perform risk assessment using an “all‐hazards” approach, focusing on capacities and capabilities– Consider internal, external, man‐made and natural emergencies/disasters– Consider care‐related, equipment and power, communications, cyber‐attacks, loss of facility, system of medical

documentation that preserves patient information, maintains availability of records)– Identify State and Local requirements

– Policies and Procedures• Develop and implement policies and procedures based on the emergency plan and risk assessment

– Address a range of issues including: subsistence needs, evacuation plans, procedures for sheltering in place, tracking patients and staff during an emergency.

– Communications Plan• Develop a communication plan that complies with both Federal and State laws

– Coordinate patient care within the facility, across health care providers, and with state and local public health departments and emergency management systems.

– Training and Testing• Develop and maintain training and testing programs, including initial training in policies

– Test plan annually (Facility‐based (specific), Full‐scale (community), and Table‐Top (internal group discussion)



• HHA Action: By November 15, 2017 – In place (including completed training and testing) by November 15, 2017

• Review current Emergency Preparedness program

• Review final rule

• Identify state and local requirements

– Establish patient triage criteria and procedures based on the patient's medical and psychiatric condition and home environment.

• Plans for the HHA's patients during a natural or man‐made disaster.

• Individual plans for each patient as part of the comprehensive patient assessment

• Procedures to inform state and local emergency preparedness officials of patients in need of evacuation from their residences.

12/20/2017



• HHA Action: By November 15, 2017 • Identify emergency preparedness team

• Identify state, local, community, provider association, on‐line resources

• Collaborate with governmental and nongovernmental sources

• Collaborate/partner with other providers

• Identify equipment, communication, documentation materials

• Develop communication plan (internal and external)

• Address staffing, surge needs

• Create training program

• Identify staffing

• Train & test staff

• Develop and carry out exercises

• Finalize policies and procedures



§484.105 Condition of Participation: Organization and Administration of Services

• Standard: Governing Body– Assumes full legal authority and responsibility for:

• Overall management and operation• Provision of all home health services• Quality assessment and performance improvement program• Fiscal operations

– Review of agency’s budget, operational plans• Fraud and abuse detection, amelioration

• HHA Action: By January 2018 – Review/rewrite governing body criteria, qualifications, duties and responsibilities– Establish agency policies and procedures

• Determine communication means, frequency meetings

– Recruit appropriate members– Educate governing body

12/20/2017



• Standard: Administrator– If employed on or after January 13, 2018 (if change finalized), a person who:

• Is a licensed physician, a registered nurse, or• Holds an undergraduate degree; and has experience in health service administration,

with at least 1 year of supervisory or administrative experience in home health care or a related health care program.

• Duties and Responsibilities– Appointed by and reports to governing body– Responsible for all day‐to‐day operations of the HHA– Ensures that a clinical manager is available during all operating hours– Ensures HHA employs qualified personnel– Development of personnel qualifications and policies– Available (or pre‐designated person) available during all operating hours




• Standard: Clinical Manager– A person who is a licensed physician, physical therapist, speech‐language

pathologist, occupational therapist, audiologist, social worker, or a registered nurse

– Duties and Responsibilities• One or more qualified individuals

• Provide oversight of all patient care services and personnel

• Oversight must include the following – Making patient and personnel assignments

– Coordinating patient care

– Coordinating referrals

– Assuring that patient needs are continually assessed

– Assuring the development, implementation, and updates of the individualized plan of care

12/20/2017



• HHA Action: By January 2018– Create/revise administrator, clinical manager job descriptions/qualifications

– Amend policies as needed

– Identify/hire administrator, clinical manager(s) that meet qualification

– Secure governing body approval of administrator

– Secure written administrator/governing body approval of acting administrator

– Orient to roles/responsibilities

– Train all staff in role of administrator/clinical manager



IG Concerns

• The use of contract staff in a direct service must be on a temporary basis to provide coverage for an unexpected staffing shortage or to provide a specialized service that the direct employees cannot provide

12/20/2017



§484.110 Condition of Participation:Clinical Records

• Standard: Content of the Clinical Record– Be available to the physician(s) issuing orders for the home health plan of care, and staff– Contact information for the patient, the patient’s representative (if any), and the patient’s primary

caregiver(s) – Contact information for after discharge primary care practitioner or other health care professional

responsible care – Transfer summary

• A completed transfer summary that is sent within 2 business days of a planned transfer, if the patient’s care will be immediately continued in a health care facility; or

• A completed transfer summary that is sent within 2 business days of becoming aware of an unplanned transfer, if the patient is still receiving care in a health care facility at the time when the HHA aware of the transfer

– Discharge Summary: A completed discharge summary that is sent to the primary care practitioner or other health care professional who will be responsible after discharge

• Within 5 business days of the patient’s discharge; or

• Standard: Retrieval of Clinical Records– Must be made available to a patient, free of charge, upon request at the next home visit, or within 4

business days (whichever comes first)


§484.110 Condition of Participation:Clinical Records

• HHA Action: By January 2018 – Conduct clinical record analysis

– Identify required content additions

– Consult with software vendor

– Review and revise policies and procedures to ensure• Timing of entries

• Contact information of patient representative, caregiver (if any)

• Contact information of physician responsible for Plan of Care

• Contact information practitioner caring for patient after discharge

• Timelines for

– Provision of discharge/transfer summary

– Provision of record upon patient request

12/20/2017



IG Concerns

• IG Statement– All HHA staff must receive comprehensive and periodic training on the protection

of patient clinical records– Typical Discharge/Transfer content

• Admission and discharge dates;• Physician responsible• Reason for admission to home health• Type of services provided and frequency• Laboratory data;• Medications the patient is on a discharge;• Patient’s discharge condition• Patient outcomes in meeting the goals• Patient/family post‐discharge instructions


12/20/2017



2017 HEALTHCAREfirst Enhancements

• Exciting HEALTHCAREfirst Partnerships– MEDsys EVV Interface

– ABILITY Interface / firstREV

– Medline Medical Supply Interface

– Optum PBM Interface

• Enhancements in 2017– HEALTHCAREfirst’s EHR Software, innovative, fresh new look

– Care Planning

• CAREpliance™ Technology in firstHOMECARE


Thank You

• On‐demand video will be made available following the webinar.

• We want to hear from you! Please fill out the survey.

Contact HEALTHCAREfirstwww.healthcarefirst.com

[email protected]

Home Health Regulatory Update - Amazon S3 · PDF file• Removed the measure for Drug...

Documents

Transcript of Home Health Regulatory Update - Amazon S3 · PDF file• Removed the measure for Drug...