Home Health & Hospice Week

CMS can’t do much for non-Medicare facilities.

Home care providers are facing a wide array of critical challenges in the face of COVID-19, ranging from PPE shortages to staffing shortfalls to reimbursement hits. But home health and especially hospice agencies are also encountering another big problem: accessing patients who need their services in facilities.

Skilled nursing, assisted living, independent living, and other facilities are drastically limiting visitors — often including HHA and hospice staff.

In the Centers for Medicare & Medicaid Services’ latest weekly COVID-19 call for home health and hospice agencies, three hospice speakers highlighted the access problem. Hospice staff are getting “lumped in” with visitors and not allowed in, noted physician Balu Natarjan, chief medical officer for the Seasons Hospice chain based in Rosemont, Illinois.

“We want to get in, but we can’t get in,” said Katy Lanz, founder of consulting firm Topsight and National Hospice and Palliative Care Organi­zation board member.“We just can’t get to people,” Lanz said in the call.

Some facilities insist that they are doing end-of-life care on their own, but “things are missing,” said Susan Ponder-Stansel, CEO of the Community Hospice & Palliative Care chain based in Jacksonville, Florida.

“The coronavirus pandemic is really exacer­bating longstanding issues,” acknowledged a CMS official in the April 28 call.

Natarjan urged CMS to help hospices gain necessary access.

Home care and hospice agencies hoped some March 9 instructions from CMS to SNFs would help the matter.“If hospice care is provided in a nursing home, we have advised nursing homes that hospice workers should be allowed entry provided that hospice staff is following the appropriate [Centers for Disease Control and Prevention] guidelines for Transmission-Based Precautions, and using PPE properly,” CMS said in the memo to state survey agencies.

But the problem persists, hospices report. When it comes to assisted and independent living facilities, CMS can’t offer much help.

“CMS does not regulate these facilities, as they are subject to state jurisdiction,” the agency says in a revision to its memo to state survey agencies, Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (COVID-19) in Home Health Agencies (HHAs) and Religious Nonmedical Healthcare Institutions (RNHCIs).CMS added RNHCIs in an April 23 update.

“HHAs are encouraged to coordinate with assisted living/independent living facilities to assure services related to direct clinical care can be provided in an appropriate and safe manner,” the updated memo continues.“If the HHA staff are appropriately wearing PPE, and do not meet criteria for restricted access, they should be allowed to enter and provide services to the patient.”

HHAs will have some responsibilities, though.“HHA personnel should participate in any screening activity that the facility requires,” CMS stipulates in the update.“If access is restricted, HHAs should communicate with the facility administration, including the state or local health department when indicated, on the nature of the restriction and timing for gaining access to HHA patients.”

“We recognize … that the services you are providing are important,” the CMS official said in the April 28 call. But agencies will have to work it out with the state.

Helpful: Make sure facility partners under-stand your staff are following all CDC procedures, the CMS staffer advised.

Note: The updated HHA guidance memo is online at www.cms.gov/files/document/qso-20-18-hha-revised.pdf.