HCA Offering Intro to MOLST

The Home Care Alliance is part of a state-run committee charged to provide education and outreach on Medical Orders for Life Sustaining Treatment (MOLST) and will be holding a free conference call for members on January 3rd from 1:00-2:00pm.

MOLSTAlliance staff who sit on the MOLST Community Outreach and Education Committee with state officials and other organizations will provide an overview of the standardized form being used to translate a patient’s life-sustaining treatment preferences into a medical order that can be honored across all healthcare settings.

Jeanne Ryan, Alliance Board Member and Executive Director of the VNA & Hospice of Cooley Dickinson, will be on the call to explain how that agency worked with their provider partners to educate their community about MOLST and related issues.

Again, the call is free for HCA members who sign up by contacting James Fuccione at the Alliance.

To download the actual form and to find more information on MOLST, visit www.molst-ma.org.

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Timeline Updated for Dual-Eligible Care Demonstration

MassHealth and CMS have agreed to a new implementation timeline for the statewide demonstration to better integrate and coordinate health care services for dually eligible individuals between the ages of 21 and 64.

Obviously, the deadline for selectionselection of ICO’s, or Integrated Care Organizations, has come and gone, but the “readiness review” for those ICO’s has been extended. Previously, the demo was set to begin enrollment on April 1st, but it now appears that the state and CMS have agreed to have the first self-selected enrollments to become effective on July 1st.

See the updated timeline below and visit the state’s demonstration webpage for more info:

ICO Selection Announcement

November 2, 2012

Readiness Review

Nov. 2012 – March/April 2013

3-Way Contracts

March/April 2013

Learning Collaboratives

March 2013 – Ongoing

Implementation Activities


       Stakeholder Workgroups: Quality, Notices, Outreach, Admin. Simplification

Dec. 2012 – Ongoing

     Implementation Council

Feb. 2012 – Ongoing


May 2013 – Ongoing

Public Awareness Campaign

April 2013 – Ongoing

Member Outreach Activities

(Members can begin to select ICOs for effective date July 1, 2013)

May 2013 – Ongoing

Self-Selected Enrollments Begin

July 1, 2013

Auto-assignments Effective

(Members notified at least 60 days prior to the effective date)

Oct. 1, 2013; Jan. 1, 2014

Planned Revisions to Home Health Beneficiary Notice-Open for Public Comment

Presently home health agencies (HHAs) are required to use the Home Health Advance Beneficiary Notice (HHABN), CMS-R-296 to provide beneficiaries with change of care notification consistent with HHA Conditions of Participation (COPs) in addition to its liability notice function. Option Box 1 addresses liability, Option Box 2 addresses change of care for agency reasons, and Option Box 3 addresses change of care due to provider orders.

In CMS’ effort to “streamline, reduce, and simplify notices to Medicare beneficiaries,” HHABN Option Box 1, the liability notice portion, will be replaced by the existing Advanced Beneficiary Notice of Noncoverage (ABN) which is approved by Office of Management and Budget (OMB) for conveying information on beneficiary liability. CMS will introduce the “Home Health Change of Care Notice” (HHCCN) as a separate, distinct document to give change of care notice in compliance with HHA conditions of participation. The HHCCN will replace both Option Box 2 and Option Box 3 formats of the HHABN. The single page format of the HHCCN is designed to specify whether the change of care is due to agency reasons or provider orders. Form Number: CMS–10280 (OCN: 0938–New) To obtain copies of the supporting statement and any related forms for the proposed paperwork collections referenced above, go to CMS’ Web Site address at http://www.cms.hhs.gov/, or Email your request, including your address, phone number, OMB number, and CMS document identifier, to Paperwork@cms.hhs.gov, or call the Reports Clearance Office on (410) 786-1326.

The full notice and details for submitting public comments on the proposed changes can be accessed in the Federal Register.  Comments are due by February 11, 2013

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CMS Updates Policy Requirements for Medical Record Corrections

CMS released Transmittal 442, Change Request (CR) 8105 on December 7th. It provides instructions to Medicare contractors regarding amended, corrected, and delayed entries in medical records. This updates the CMS Medicare Program Integrity Manual, Section effective January 8, 2013.

According to this Change Request, the MACs, CERT, Recovery Auditors, and ZPICs are instructed NOT to consider entries that don’t comply with recordkeeping principles, even if exclusion of an entry will result in a claim denial.

In the manual update, “providers are encouraged to enter all relevant documents and entries into the medical record at the time they are rendering the service.” However, the policy goes on to acknowledge that there may be occasions when documentation was not completed or completed properly and may need to be amended. Medicare contractors are told that they are to consider all submitted entries that comply with the widely accepted Recordkeeping Principles, but NOT consider any entries that do not comply with the principles.

Recordkeeping principles for record amendments apply to both paper and electronic medical records. These principles include:

  • Clearly and permanently identify any amendment, correction or delayed entry as such; 
  • Clearly indicate the date and author of any amendment, correction or delayed entry; 
  • Not delete but instead clearly identify all original content.

When correcting a paper medical record, the “principles are generally accomplished by using a single line strike through so that the original content is still readable. Further, the author of the alteration must sign and date the revision. Similarly, amendments or delayed entries to paper records must be clearly signed and dated upon entry into the record.”

CMS acknowledges that although “record keeping within an EHR deserves special considerations” the same principles apply. EHR corrections or delayed entries must:

  • Distinctly identify any amendment, correction or delayed entry, and;
  • Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.

The manual update also states “If the MACs, CERT or Recovery Auditors identify medical documentation with potentially fraudulent entries, the reviewers shall refer the cases to the ZPIC and may consider referring to the RO and State Agency”.

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Encore-Special ODF for Hospice Providers

Did you miss the December 19th Open Door Forum that presented information about the Hospice Quality Reporting Program?

CMS announced that this ODF will have an encore recording available until midnight December 22nd

Agenda Topics included:

  • Updates about the upcoming availability of the data submission website
  • Information about how to access the data submission website and create a user account
  • Details about the data submission process
  • Question and Answer session

ENCORE CALL IN:  1-855-859-2056



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DPH Mandates-Electronic Submission of Plans of Correction

The MA Department of Public Health, Division of Health Care Quality, recently announced in Circular Letter 12-12-577 effective January 1, 2013, certified facilities, agencies and providers will be required to submit Plans of Correction (POC) by email for all statements of deficiencies.

DPH has created three email addresses to ensure that POCs can be submitted to the appropriate surveyors and regions for review:

Detailed instructions for the submission of POCs by email, including the specific email address to which the POC should be sent, will be included in the cover letter to the facility for each Statement of Deficiency.

The following must be observed when submitting POCs by email:

  • Title the email “[Facility/agency name] POC for Survey Ending [date of survey]
  • Scan the POC, signed and dated, separately from any supporting documentation
  • Scan the POC and supporting documentation as separate .pdf files
  • Name the scanned files using the facility name and ending date of the survey
  • Do not send a hard copy of the POC by mail or fax when emailing a POC

When the POC is received at the appropriate email address, the agency/provider will receive an automated response indicating that the POC has been received. Addressing the email with a facility name and date of survey will generate an auto-reply email which will serve as a receipt for the initial submission of a POC, and indicate that the POC has been received by the Department and is being processed for review.

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Four Reasons to Choose An Agency Over A Direct Hire

This month, the Alliance is mailing nearly 5,000 copies of its latest publication, 4 Reasons to Choose An Agency Over A Direct Hire to every Council on Aging (COA) and Aging Access Service Point (ASAP) in the state.  Additionally, packages of up to 50 copies of the brochure are available on the Alliance’s website at no charge.

This postcard-sized brochure is professionally printed on heavy card stock and is intended for families uncertain why they should choose an agency.  On the front, it describes four areas where home care agencies have a distinct advantage over direct hires; on the anterior, it provides a “Quality Home Care Checklist” to help visualize these benefits.

Front page Anterior side

The full text of the front page reads:

Why should your family work with a Home Care Alliance of Massachusetts member agency rather than hire an aide or nurse directly? Home care agencies provide significant benefits over direct hires in the areas that matter most to families:

    1. Employer Obligations: By hiring an aide or nurse directly, you take on the legal responsibilities of an employer, including paying payroll taxes, workers compensation, unemployment insurance, and liability. Working with a Home Care Agency alleviates you of these responsibilities.
    2. Peace of Mind: The only background checks that come with a direct hire are those you do yourself. Home Care Agencies, however, are required to conduct criminal background checks and have access to more comprehensive data than is available to the public.
    3. Security & Contingency: If your direct hire harms or steals from you, you’re on your own. In contrast, Home Care Agencies are required to carry various forms of insurance to protect you. Additionally, agencies can quickly provide a replacement if your aide or nurse is sick, injured, or changes jobs.
    4. Training & Supervision: You are responsible for training and supervising your direct hire. Home Care Agencies, however, have the experience, knowledge, and resources to ensure their workers are thoroughly trained in any services or tasks they perform, including safe infection control, falls prevention, emergency preparation, and personal care tasks.

How do you know an Agency is doing these things correctly? Don’t be afraid to ask them directly, or check to see if they’re a member of the Home Care Alliance of Massachusetts at http://www.thinkhomecare.org/agencies.

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