Home Health & Hospice Week

Plus: More OIG audits focusing on telehealth are in the offing.

Home health agencies aren’t out of the COVID woods yet, but analysis of their response to the pandemic is already front and center.

In a new report released Oct. 18, Home Health Agencies Used Multiple Strategies To Respond to the COVID-19 Pandemic, Although Some Challenges Persist, the HHS Office of Inspector General focuses on several key pandemic topics including staffing challenges, telehealth provision, regulatory flexibilities, and emergency preparedness.

To get a feel for how HHAs responded to the COVID-19 pandemic and public health emergency, the OIG surveyed a sample of agencies, receiving 271 responses, it says in the report.

One of the earliest problems to hit HHAs was accessing personal protective equipment (PPE) for staff, agency representatives told the watchdog agency. Nearly all agencies reported difficulty accessing masks and other types of PPE as well as sanitizing products. And the cost of those when they could access them was high.

By fall 2021, when the OIG conducted its survey, most HHAs’ PPE access problems had faded. However, the high cost of PPE still troubled 42 percent of agencies that responded, they said.

Another problem hasn’t faded, but has changed over the course of the pandemic— staffing. Early in COVID, quarantine and isolation due to COVID-19 exposure and inability to work due to “personal circumstances related to the pandemic,” such as having school-aged children at home, topped agencies’ list of challenges. In fall 2021, recruiting staff in competition with other types of healthcare providers was HHAs’ biggest reported problem.

Whatever the problem, staffing is still a huge issue for HHAs. Those surveyed reported using the following strategies to help:

• Provided paid and/or unpaid leaves of absence to retain staff that are unable to work (65 percent);
• Provided staff benefits to address COVID-19-related concerns, such as flexible schedules (59 percent);
• Trained staff to perform tasks outside of their usual duties (58 percent);
• Created specialized care teams of clinical staff who treat only COVID-19 patients (40 percent); and
• Developed new partnerships or used existing part- nerships with other HHAs or health care facilities to share staff to fill staffing gaps (27 percent).

Agencies Will Quit Using Telehealth If Medicare Doesn’t Pay, They Say

Likewise, telehealth was a big change for many HHAs in the pandemic. About 73 percent of responding agencies reported using telehealth during COVID. Telehealth services ranged from providing real-time, live services to patients to setting up telehealth calls between patients and non-HHA physicians to transmitting patient information to providers for asynchronous assessment.

Survey respondents reported some big problems with telehealth provision, however. For rural HHAs especially, the availability of internet access was a significant barrier to telehealth provision.

For HHAs in general, the cost of purchasing equipment and furnishing services without direct Medicare reimbursement was a big issue. That was one factor contributing to the 43 percent of agencies that said they wouldn’t use telehealth after the pandemic is over, unless the reimbursement picture changes.

Watch out: An OIG “audit is underway to examine HHAs’ compliance with regulations for telehealth services — i.e., the regulations that were initially limited to the duration of the public health emergency, but subsequently made permanent,” the report notes.

On the regulatory flexibility front, HHAs ranked “Authorizing additional practitioners to certify beneficiaries for eligibility, order home health services, and establish and review the care plan” as the number-one helpful waiver at 80 percent.

Other popular flexibilities were allowing occupational therapists, physical therapists, and SLPs to perform certain assessments for all patients receiving therapy services (64 percent); extending the five-day completion requirement for the comprehensive assessment to 30 days (54 percent); waiving the requirement for onsite visits by a nurse every two weeks (48 percent); and postponing the deadline for certain training requirements for home health aides (41 percent).

Regarding emergency preparedness plans, most HHAs reported finding their EP plans useful, but lacking in certain areas. Chiefly, “because HHAs’ EP plans generally focused on local, temporary emergencies, many fell short in a sustained, global emergency,” the OIG notes.

“HHAs expressed that they would benefit from more support from [the Centers for Medicare & Medicaid Services] on developing and using their EP plans to meet the challenges of an infectious disease emergency,” the report adds.

Based on its survey and other information, the OIG recommends that CMS evaluate how HHAs are using telehealth; assess how regulatory flexibilities affect care quality with an eye towards possible permanent implementation; and work with the Administration for Strategic Preparedness and Response’s (ASPR’s) Technical Resources, Assistance Center, and Information Exchange (TRACIE) to help furnish training and materials for HHAs on EP planning.

CMS Administrator Chiquita Brooks-LaSure agrees with those recommendations in a response to the report, noting that CMS is already working on all three areas and more besides. For example, CMS’ 2023 home health proposed rule proposes telehealth reporting that would be voluntary starting in January 2023 and mandatory starting in July.

Note: The 61-page report is at https://oig.hhs.gov/oei/reports/OEI-01-21-00110.pdf.