Home Health & Hospice Week

Aide training, volunteers addressed in latest Medicare updates.

Watch out: The Centers for Medicare & Medicaid Services is changing and adding information to its PHE waiver fact sheets ... again. To be prepared, you’ll need to keep up to date on the latest revisions.

Recap: On Jan. 30, the White House released a statement setting the PHE’s end date on May 11, and CMS updated its related fact sheets on Feb. 1 (see HHHW by AAPC, Vol. XXXII, No. 5). Then on Feb. 9, the Department of Health and Human Services issued a final PHE renewal that went into effect on Feb. 11 and offered providers advice on transitioning to a post-PHE landscape in a “Roadmap” document (see HHHW by AAPC, Vol. XXXII, No. 7).

Most recently, on Feb. 24 CMS offered more changes and updates to its 17 different fact sheets, including those for home health and hospice providers.

For example: In the Feb. 1 update, CMS addressed the requirement that each home health aide receive 12 hours of in-service training in a 12-month period, saying it was “postponing the deadline for completing this requirement … until the end of the first full quarter after the declaration of the PHE concludes,” i.e., September 2023. Now, the newly updated sheet says “this flexibility will end at the conclusion of the PHE and return to pre-PHE requirements at the end of the calendar year that the PHE ends,” i.e., December 2023.

Another example: In the Feb. 1 update, CMS offered no grace period for the reinstated requirement for hospices to use volunteers. Now, the fact sheet notes that “this flexibility is currently set to return to pre-PHE requirements at the end of the calendar year that the PHE ends. This waiver will terminate at the end of the COVID-19 PHE,” apparently indicating hospices have until Dec. 31, 2023, to get back up to speed on the volunteer front.

The latest: On Feb. 27, CMS released another resource, the “What Do I Need to Know” fact sheet, to help providers prepare for the PHE’s end. The overview doesn’t get into many provider-specific details, but does address telehealth services furnished in patients’ homes.

“Companies relying on the PHE waivers should take steps now to bring operations into full compliance with applicable requirements before the PHE ends in May,” urge attorneys Thomas Ferrante and Rachel Goodman with law firm Foley & Lardner. “Companies should also closely monitor further changes, or adjustments to expiring flexibilities that may be announced in the coming months,” Ferrante and Goodman advise in online legal analysis.

With the PHE’s end looming ever closer, “providers must quickly review their operations and ensure their continued compliance with billing requirement changes that will result from the PHE’s expiration,” recommends law firm Proskauer Rose in an online law brief.