Home Health & Hospice Week

Make sure you’re up to date when Medicare’s EP requirements hit in November.

Home care and hospice providers work on their emergency preparedness plans in the hopes that they’ll never need them. But Texas and Louisiana agencies in the path of Hurricane Harvey have had those hopes dashed.

At press time, Hurricane and then Tropical Storm Harvey had dumped more than 52 inches of rain on some parts of Texas, and the storm continued to pummel parts of the Louisiana Gulf Coast. The amount of rain is unprecedented, experts say.

The resulting flooding has wreaked havoc on residents of Houston and parts of the Texas and Houston Gulf Coast — including on many home health and hospice patients, as well as employees and offices of the home care providers who care for them. About 30,000 people have sought refuge in temporary shelters, government officials estimated.

The Department of Health & Human Services declared a Public Health Emergency for affected Texas areas on Aug. 26 and Louisiana on Aug. 28. “As Louisiana and Texas contend with the historic flooding caused by Hurricane Harvey, HHS is committed to doing all that we can to ensure that those affected by this storm receive the vital assistance and support they need,” HHS Secretary Tom Price said in release. “The people of Louisiana who rely on Medicare, Medicaid, and CHIP for their healthcare needs can be confident that this declaration will allow their care to continue despite the toll this disaster has taken in their communities.”

Due to the emergency declaration and other actions taken by HHS, the Centers for Medicare & Medicaid Services is able to waive certain documentation requirements to help ensure healthcare providers can deliver care to patients who have no health records, or even no proof of their Medicare status, the HHS release noted. “In addition to increasing the flexibility in providing assistance for CMS beneficiaries, HHS has deployed approximately 550 personnel to affected areas to help state and local authorities respond to communities’ medical needs, and additional staff is on standby to assist.” CMS issued the 1135 waiver in conjunction with HHS’s Public Health Emergency declaration, CMS notes on its emergency webpage.

Providers must apply for a waiver from CMS for certain documentation requirements. But CMS has approved a “blanket waiver” for this requirement for all HHAs in the affected area, it notes on its Hurricane webpage: “484.20(c)(1): This waiver provides relief to Home Health Agencies on the timeframes related to OASIS Transmission. (Blanket waiver for all impacted agencies).”

Home Care Providers Step Up

Despite the flooding and other weatherrelated problems, agencies in Harvey’s path were quick to respond to the emergency. Corpus Christi, Texas-based home health billing company Astrid Medical Services saw its own share of flooding, as did multiple clients in the Houston area, Astrid owner Lynn Olson told Eli.

But Astrid and all but one of its Houston HHA clients were up and running as of Aug. 30. “Life is good,” Olson said.

Louisiana HHAs saw some “intense rain and flooding,” noted Pam Warmack, consultant with Clinic Connections in Ruston, Louisiana. “The areas most seriously affected in Louisiana are those parishes in Southeast Louisiana,” which contain about 300,000 people, Warmack notes.

“As far as I am aware, all Louisiana providers are open and taking care of business to the best of their abilities,” Warmack reported at press time.

National chain Kindred at Home has “a plan to take care of our home health and hospice patients who need services,” Kindred Healthcare CEO Benjamin A. Breier said in an Aug. 28 release. “We are focused on doing everything necessary to support our team in Houston to make sure that our sites of service are operational, our patients safe, and our employees have support under very difficult circumstances.”

The affected agencies’ abilities to respond quickly to the hurricane and its aftermath may have been aided by the providers’ preparations for Medicare’s new Emergency Preparedness rule.

Reminder: The Centers for Medicare & Medicaid Services published an EP final rule in September 2016. It had an effective date of Nov. 16, 2016 and a compliance date of Nov. 16, 2017. Then CMS published the interpretive guidelines for the rule in June (see Eli’s HCW, Vol. XXVI, No. 22).

Among other requirements, the rule mandates that providers complete a training and testing program, including testing “exercises,” by the November 2017 deadline.

“Most providers have been busy upgrading their emergency preparedness plans due to the new regulations going into effect in November,” Warmack says. “So at least everyone has had EP on their mind.”

Perspective: Consultant Katie Wehri with Healthcare Provider Solutions in Nashville believes “that agencies that were preparing for the new EP rule were much more prepared and had better results,” Wehri tells Eli. “Any agency in the area of impact by Hurricane Harvey that was not working on the rules going into effect in November likely had a wake-up call to ensure plans are in place — not just for the sake of meeting the deadline, but for the sake of the best outcome under an emergency situation.”

Home Care Gives Back

Providers in the hurricane’s path aren’t the only ones who have stepped up in the storm. Agencies across the nation have taken action.

For example: Right at Home in Colorado Springs, Colorado, collected donations for those affected by Harvey, reports Fox 21 News. Right at Home’s owners, who are Houston natives, planned to drive the supplies down themselves.

Another example: And Kindred Healthcare joined the long list of companies that donated cash to Harvey relief efforts. Kindred donated $50,000 to the American Red Cross for Harvey recovery, it notes in its release.

Kindred “is also supporting its employees through its HOPE Fund, a tax-exempt charitable organization that was established to provide monetary assistance to Kindred employees experiencing financial hardship due to a catastrophic life event,” the Louisville, Kentucky-based chain says. “Many of our employees are not only stepping up to take care of our patients under very trying circumstances, but they also face their own personal and financial challenges in the wake of this devastating storm. We are committed to supporting them in the aftermath of this tragedy.”

About 80 percent of houses flooded by Harvey aren’t covered by flood insurance, according to press reports. Government officials said they expected more than 450,000 people to file for disaster assistance due to flooding.

In an Aug. 28 press conference, the Federal Emergency Management Association warned that “the state of Texas is about to undergo one of the largest recovery-housing missions that the nation has ever seen,” according to press reports. “It’s a long process. Housing is going to be very frustrating in Texas. We have to set the expectations.”