New Emergency Prep 4-Part Webinar Series

Agencies continue to struggle with the development of a disaster preparedness plan that will not only be in compliance, but realistic in an event. Areas of weaknesses in the process have been identified by CMS and accrediting bodies. On top of that, there were changes made to regulations at the end of 2018 and appeared in the 2019 interpretive guidelines. This series of one-hour webinars will provide in-depth knowledge of the requirements that home health and hospice organizations are subject to, with specific focus on: an overview of the regulations, starting the agency-specific plan, building the plan, development of policies and procedures, communication, and testing and training.

Program Goals: Through attendance in this web series, participants will increase their understanding of the newly updated federal emergency preparedness requirements that are part of the home health and hospice
Conditions of Participation (CoPs) and become knowledgeable in how to apply the federal requirements for disaster preparedness in their own specific agencies. Enhance disaster plan development for all community based agencies.

Following is the planned content and schedule for the live webinar sessions; for those who are unable to attend the live sessions, recorded sessions will be available.
Please note there is limited seating in the live sessions so please register early.

Part 1: OVERVIEW OF THE REGULATIONS – June 4, 2019, 1:00-2:00 pm EDT
Including Lessons Learned, Home Health and Hospice’s Role in an Event, All-Hazards Approach, Regulatory changes since 2018 and survey findings from the first year under the disaster preparedness CoPs.
Part 2: STARTING AND BUILDING THE PLAN, – June 11, 2019, 1:00-2:00pm EDT
Including Four Phases of Emergency Management, Incident Command System, and Hazard Vulnerability Assessment , Infection control and prevention, Continuity of Operations (Defining Essential Function, Succession Planning, Human Resources, Alternate Location, Defining Patient Populations, and Data Management)
Part 3: DEVELOPMENT OF POLICIES AND PROCEDURES – June 18, 2019, 1:00-2:00 pm EDT
Patient Classification Systems, Transportation Classifications, Surge Capacity, HIPAA/IT, Tracking Patients and Staff, and Roles and Definitions., Organizing the plan.
Part 4: COMMUNICATION/TESTING AND TRAINING – June 25, 2019, 1:00-2:00 pm EDT
Health Care Coalitions; Specific Hospice Requirements; MOUs; Government Emergency Telecommunications System; Collaborative Relationships with Local, State, Federal, and Indian Tribe Nations; Annual/Orientation Requirements, Documentation of Training, Types of Exercises (Tabletop, Functional, Full-scale), After Action Report, Revising and Updating the Plan

REGISTER AT:
https://www.rbclimited.com/product/edp-4-part-series/

DISCOUNT CODE: RBCEDP

Good for all community-based, home care, hospice & Medicare certified home health agencies

A New Version of OASIS is Coming!

Is your staff just getting used to completing OASIS-D?  Surprise,   CMS recently announced there will be a new version for 2020!

It was a surprise to many when CMS declared during the April 3rd, Open Door Forum, that effective January 1, 2020 there would be a new version of OASIS. I know I was thinking at first that the presenter misread the effective date, but apparently this update is needed to support the Patient Driven Grouping Model (PDGM).  One more thing for HHA to deal with. But, HCA of MA will be here for you.  (See link at end to out Fall 2019 OASIS training.)  

Thankfully though, after reviewing the  CMS Memorandum,   I realize that there are only a few minor changes.

Quick synopsis:   Two items will be added to the Follow-Up assessment:  M1033-Risk for Hospitalization and M1800-Grooming. These items should pose no problem since staff is familiar with answering these items at SOC/ROC. Surprisingly, the other change involves the “option” to no longer answer 23 items!  Rather than leaving the items blank,  the clinician will be required, however,  to respond by using the equal sign (=).

Here are the “optional” items for your convenience.

Start of Care/Resumption of Care (SOC/ROC)

• M1910 Fall risk Assessment

Transfer (TRN) and Discharge (DC)

• M2401a Intervention Synopsis: Diabetic Foot Care

• M1051 Pneumococcal Vaccine

• M1056 Reason Pneumococcal Vaccine not received

Follow-Up (FU)

• M1021 Primary Diagnosis

• M1023 Other Diagnoses

• M1030 Therapies

• M1200 Vision

• M1242 Frequency of Pain Interfering with Activity

• M1311 Current Number of Unhealed Pressure Ulcers at Each Stage

• M1322 Current Number of Stage 1 Pressure Injuries

• M1324 Stage of Most Problematic Unhealed Pressure Ulcer that is Stageable

• M1330 Does this patient have a Stasis Ulcer

• M1332 Current Number of Stasis Ulcers that are Observable

• M1334 Status of Most Problematic Stasis Ulcer that is Observable

• M1340 Does this patient have a Surgical Wound

• M1342 Status of the Most Problematic Surgical Wound that is Observable

• M1400 Short of Breath

• M1610 Urinary Incontinence or Urinary Catheter Presence

• M1620 Bowel Incontinence Frequency

• M1630 Ostomy for Bowel Elimination

• M2030 Management of Injectable Medications

• M2200 Therapy Need

HCA of MA next Blueprint for OASIS Accuracy will be held on November 4th and 5th. Option to take the certification exam will be on the 6th.

You can register for the course here.

Blog post by:  Colleen Bayard.

Electronic Visit Verification (EVV) System Resource Page Now Available for HCA Members!

The Home Care Alliance of MA is happy to announce a resource page completely dedicated to keeping Home Health Care Providers informed for the upcoming Electronic Visit Verification (EVV) Mandate. You can access this page by going to www.thinkhomecare.org/EVV

Massachusetts Executive Office of Elder Affairs is moving forward with “deliberate speed” to implement the federal EVV mandate.  Massachusetts is developing a hybrid model for EVV, allowing agencies to use their current EVV vendor or choose any vendor that can collect and transmit the required data elements.  For those agencies without an EVV vendor, Massachusetts has contracted with Optum to design a free EVV system.  The current schedule would require personal care agencies that participate in the MA Home Care program that currently have an EVV system in place to begin testing in late 2018. Personal care agencies that don’t currently have an EVV system in place will have additional time to either go live with the Optum system or select and implement an EVV system from another vendor.

According to data collected by EOEA, well over half of the EOEA home care provider agencies in MA do not currently have an EVV vendor.  These agencies will have to make important purchasing decisions within the next year. This page is created to provide the must up to date information on EVV including important resources, vendor information and more.

EVV Vendor Webinar Series

Along with access to to important documents, websites, and contact information – HCA of MA has developed a monthly webinar series that allows EVV Vendors a one hour webinar to demonstrate their platform to our members for FREE! The webinars are typically held the 2nd Tuesday of every month and are recorded in the case you cannot listen to the series live.

The current schedule is as follows:

March 19th – Agency Workforce Management (Recording Available)

April 9th – HHAeXchange (Recording Available)

April 23rd – CellTrak

May 14th – Homecare GPS

June 11th – HomeCareIT

July 9th – Sandata

August 13th – 4Tellus

September 10th – ClearCare

REGISTER ONLINE

*Registering online gains you access to all webinars currently scheduled and any future webinars that may be scheduled

 

EVV Implementation: One Agency’s Experience

One additional resource webinar will be a one hour program with an agency member: HebrewSenior Life. Members of the HSL Leadership Team as they share their experience with implementing an EVV platform.  They will offer product highlights and the benefit and impact experience for clients, workforce, operations, and finances. They will also share their approach to the establishment of policies, procedures, and timelines for success with onboarding for caregivers and leaders.

This webinar will be held on Wednesday, April 24 at 1:00PM. This is also FREE to members!

REGISTER HERE

Access the EVV Resource page at: http://www.thinkhomecare.org/EVV

How CMS Stole Home Care Christmas!

Every person in Home Care liked caring a lot.
But the Grinches south of Baltimore, they surely did not!
The Grinches hated home care, delivered in any which way.
Now, please don’t ask why. No one knows what to say.

It could be CMS didn’t have a mom or a dad.
It could be their jobs were incredibly sad.
But, the most likely reason was this just this my dear,
Their hearts were hijacked by nasty old fear.

They feared the support, the need and the caring.
“It has to stop now,” they said, nostrils flaring!
“I hate all their teamwork! I despise all they do!
I’ll pick them all off, one-by-one, two-by-two!”

With a laugh and snort, they sneered, “I know just what to do!”
And put pen to paper to plot their evil, awful coup.
They threw it all at us, with the usual glee,
COPs, OASIS changes, and even VBP!
“I’ve ruined them now and forever, I swear,
Let’s see how you cope, how you can possibly still care!”

But across the Land of Home Care, they got down to work.
HCA had their back, a membership perk!
Every worker in home care, the small and the tall,
Still kept making visits, swearing once and for all:
“The families, they need us, and we will be there!
No Grinches in DC can stop us with fear.”

And what happened then? Well… in home they say,
Those Grinches’ hearts grew three sizes that day!
The true meaning of home care shined right on through.
They ripped up their papers, stopped pre-claim review.
“Maybe home care,” they said, “isn’t about regs, or rules.
Maybe home care is bigger, a national jewel!”

“Thank you, home care,” they said, now with a smile.
“For once, in your shoes, maybe I’ll walk a mile.
I’ll make a home visit, I’ll assist with a med.
I’ll listen to stories from clients in bed.”

“I’ve a new understanding why you do what you do.
Let’s make a new year that’s bright with a start that’s brand new!”

Return to www.thinkhomecare.org.

OASIS D-Day: Assess Once, Score Twice

In less than three weeks, home health agencies will be transitioning from OASIS-C-2 to the new OASIS D assessment. Given all the regulatory changes this year and with the holiday season upon us, it has really been a sprint to get staff trained.

HCA of MA recently held three training sessions for members and not surprisingly there is concern with staff being ready, especially around the nuanced degrees of functional assessments and specifically related to the new items related to mobility and self-care.  While OASIS-D comes advertised as “dropping 28 previous M-Items” from OASIS-C-2, the additional assessments will require lots of creative patient engagement on the part of the admitting nurse or therapist, according to HCA Director of Regulatory and Clinical Affairs Colleen Bayard.

“OASIS-D is intended to begin to standardize patient assessment and quality measures across all post-acute providers,” said Bayard. “But for us in home care some of the new items ask for very nuanced responses. For example, the mobility item (GG0170) has 17 mobility activities that  the clinician must  ‘code’ with a  6-point scale from independent to dependent or  ‘code’ with 4 possible responses related to ‘activity not attempted.’ he admitting clinician is responsible for assessing a patient’s ability to stair climb, pick up an object from the floor and even make a car transfer.

During the Alliance’s trainings, Bayard warned agencies to expect some productivity issues related to the learning curve,  but stressed that the training message across the industry should be: “assess once, score twice.” In other words, be aware of OASIS M assessment questions which track to newly added  GG assessments and use the same assessment to respond to multiple OASIS items in the same category.  Bayard also recommends close auditing or self-monitoring in the initial months, especially related to the responses “patient refused” or “dash” (not attempted). (Ask:  could the clinician interview a family member as a way to get a response?)

Bayard recommends using the “Expansion of the one Clinician Rule” to your advantage because CMS is encouraging an interdisciplinary team approach with OASIS-D. Bayard’s final advice: “As you focus on your training be aware that your nurses are going to need to have a strong intersection of observational skills with interview skills.”

HCA has several places members can come to share and learn as they move past Jan 1. Our Clinical Directors and Quality Improvement list serves and networking groups will be highly focused on OASIS-D as winter turns to spring.  The Clinical Directors next meet Thursday, January 10 and the QI Managers will next meet on January 9th. Meeting information is here. Our email groups are here.

If you haven’t already studied it – here is a list of more than 100 answers to OASIS questions received by CMS from the industry during recent CMS in-person trainings and webinars.

Return to www.thinkhomecare.org.

HCA Submits Comment on Medicare Changes; Submit Your Comments Now!

On July 1st, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule which includes several changes to the home health benefit for 2019 and beyond. The public comment period closes this Friday August 31, 2018, at 11:59 p.m. As of this blog posting, 760 comments have been submitted to CMS which is encouraging, but far from the more than 1,300 comments submitted last year in response to the HHGM proposal which was ultimately withdrawn.

You can view the HCA’s written comments here and can download the word document here.

You may submit your own comments to CMS here.

Here are some of the key changes proposed, and an overview of HCA’s response:

Home Health Wage Index Changes

  • The 2019 proposed payment rates increase by 2.1% which represents a $400 million increase.
  • HCA of MA has long expressed concerns to CMS over inequities in how the wage index is calculated for home health agencies compared to hospitals. HCA urges CMS to adjust the 2019 home health agency wage index to reflect a policy to limit the wage index disparity between provider types within a given CBSA.

Proposed Patient Driven Groupings Model (PDGM) for CY 2020

  • Implementation: As the proposed PDGM would mark a major change in the way home health agencies will be reimbursed, the HCA urges CMS to delay implementation by one year to ensure that there is no disruption in access to services for beneficiaries and evaluate the accuracy of the model and its effect.

  • LUPA Thresholds: CMS proposes to set the LUPA visit threshold at the 10th percentile for each payment group. HCA believes this is complex and will complicate the care planning process for home health agencies. HCA urges CMS to retain the current LUPA thresholds and revisit them in future years.

  • Behavioral Assumptions: CMS proposed three ‘behavioral assumptions’ in the PDGM totaling -6.42%. However, these assumptions are not based in data or evidence. HCA believes that two of the three assumptions already exist in the current PPS methodology including; that agencies are already incentivized to both report the highest playing diagnosis codes and to develop and deliver plans of care that exceed the LUPA threshold. This could result in an over estimated impact of behavioral assumptions and the HCA urges CMS to eliminate the Clinical Group Coding and LUPA threshold assumptions.

  • Split percentage payment approach: HCA believes that changing from a 60 to 30 day billing period will be very disruptive to agencies’ operations and increase back-office costs. Therefore, HCA urges CMS to continue the split payment approach at the current 60/40 and 50/50 splits for early and late periods, respectively, to give agencies cash flow breathing room.

  • Certification and Re-certification of Patient Eligibility: HCA has long advocated for regulatory language to align with sub-regulatory guidance as it relates to documentation of the patient’s eligibility. HCA is encouraged by CMS’ proposal to eliminate the requirement that the physician provide an estimate of how much longer skilled services are required and we request that CMS consider revisions to the physician’s burden of the F2F encounter as a condition of payment. 
  • Remote Patient Monitoring: HCA strongly supports the proposal to recognize remote patient monitoring costs as an administrative cost on the HHA cost report. HCA does recommend however that CMS remove the regulation that does not allow remote patient monitoring to be used as a substitute for in-person home health services. 
  • Home Health Value Based Purchasing Model: HCA has long supported the HHVBP model aiming to improve quality by giving HHAs incentives to provide better quality care. However, HCA urges CMS to modify the HHVBP to recognize stabilization in the scoring because in many cases, stabilization (instead of improvement) is an appropriate goal for some patients.

MA Legislative/Regulatory Preview for 2018

On Wednesday January 3rd , the Massachusetts Legislature returned for the second year of its two-year session. After a seven-week recess, the body is looking at a traditionally busier second half than the first. The nearly 170 bills that passed in 2017 marked the lowest total in twenty years.

Lawmakers have until July 31 to complete all substantial legislative debate. In addition, all 200 members are up for election in 2018, which is expected to be a distraction from normal legislative work as a result of a polarized political landscape. Here’s what the Alliance will be focused on in 2018:

Workforce Issues:

Prior to the Holiday break, the Alliance met with its ‘Enough Pay to Stay’ partners to strategize coordinated efforts to attain wage relief for direct care workers and ASAP case managers. The coalition has pending legislation which would take steps toward this initiative, but we will pursue other legislative vehicles to fight for our workforce.

Worker Registry:

In November, Governor Baker signed into law the Home Care Worker Registry. This law will establish a worker registry that requires agencies contracting with ASAPs to submit workers’ private information to the state. The law is enacted and subject to regulations. The Alliance and its partners are in active communication regarding next steps toward protecting our members and their workers’ rights.

Licensure:

The FY 2018 State Budget included language that will establish a licensure process for home health agencies providing skilled services. It is unclear at this point when the process to promulgate regulations will begin, but the Alliance will be providing input to the Department of Public Health as these parameters are developed. In addition, Alliance-sponsored legislation that would license private care agencies is still making its way through the legislative process. Under procedural rules, the legislature has until February to report legislation out of committee. The Alliance will continue to advocate for passage of this legislation.

Continuous Skilled Nursing:

In late 2017, MassHealth announced two rate increases for the Continuous Skilled Nursing (CSN) program that totaled nearly 11 million. This was welcomed news, but there remains work to be done. The CSN provider/parent coalition will continue to advocate for the CSN Bill of Rights legislation that would mandate bi-annual reviews of the workforce to ensure safeguards against future crises.

MassHealth Rates:

The Alliance has been informed that MassHealth will conduct a long-overdue review of rates for per-visit nursing, therapies, and home health aide services.  The Alliance will be working to gather data to demonstrate that the current low rates are interfering with agencies’ ability to attract and retain enough workers to meet the demand for services.

MassHealth Reorganization:

MassHealth’s initiative to enroll the majority of members into managed care programs this coming spring will dramatically change the way MassHealth members access home health services, and disrupt many existing provider referral relationships.  The Alliance will continue to work to ensure that MassHealth members retain access to needed home health services, and that agencies are adequately reimbursed for those services.

House of Representative Health Care Bill:

Late last year the Senate passed a health care cost containment bill aimed at curbing costs while maintaining access. It has long been rumored that the House will be embarking on similar initiatives. Though the details are scarce, this legislation could be a vehicle for many of the Alliances priorities in 2018 and we will continue to advocate where necessary.

If you have any questions about the year ahead for advocacy or would like to get involved, reach out to Jake Krilovich, the Alliance’s Director of Legislative and Public Affairs.