Home Health & Hospice Week

Plus: Enrollment liberalization may help access.

Home health and hospice agencies have a little breathing room to take on COVID-19 challenges, now that the Centers for Medicare & Medicaid Services is lifting certain regulatory requirements.

Take a look at where CMS is providing regulatory relief so far under the 1135 waiver:

• Surveys. Under the declared national emergency and public health emergency related to COVID-19, Medicare surveyors will not conduct standard inspections of a variety of providers including home health agencies and hospices, CMS said in a March 23 release.

Surveyors still will conduct complaint inspections related to Immediate Jeopardy concerns and targeted infection control inspections, CMS continued. For the latter, “inspectors will use a streamlined targeted review checklist to minimize the impact on provider activities, while ensuring providers are implementing actions to protect health and safety. This will consist of both onsite and offsite inspections,” CMS explains.

The procedure change “will allow us to focus inspections on the most urgent situations, so we’re getting the information we need to ensure safety, while not getting in the way of patient care,” CMS Administrator Seema Verma says in a release.“This is an extraordinary step designed for extraor­dinary times.”

See the announcement at www.cms.gov/newsroom/press-releases/cms-administrator-seema-vermas-remarks-prepared-delivery-updates-health­care-facility-inspections.

• Quality reporting. For post-acute care providers, including HHAs and hospices, CMS is making the reporting of quality data for the fourth quarter of 2019 — meaning deadlines for Oct.1, 2019, through Dec.31, 2019 — optional, the agency said in a March 22 release. When providers do report that data, CMS will use it for payment adjustments as usual.

HHAs and hospices also don’t have to submit quality data from Jan.1, 2020, through June 30, 2020, the first two quarters of the year, CMS said. For CAHPS, the relief extends an additional quarter, to CAHPS survey data from Jan.1 through Sept.30, 2020. See the announcement at www.cms.gov/newsroom/press-releases/cms-announces-relief-clinicians-providers-hospitals-and-facilities-participating-quality-reporting.

• Cost reports. CMS has listened to provider requests and postponed cost report filing dates.HHH Medicare Administrative Contractors CGS and Palmetto GBA say on their websites that the filing deadline for fiscal years ending Oct.31, 2019 and Nov.30, 2019 is now June 30, 2020. The more common Dec.31 fiscal year end now has a July 31, 2020 cost report due date, the MACs say.MAC National Government Services is expected to follow suit.

“This is a blanket extension; you do not need to send a request,” Palmetto instructs. Check your MAC’s website for the announcement.

• Enrollment. CMS has loosened enrollment requirements, mostly for physicians and non-phy­sician practitioners, which can help increase access to home care and hospice services with more physicians available to order those services.

For example: “NGS has established a new provider enrollment telephone hotline to allow physicians and nonphysician practitioners in our Jurisdiction … to initiate provisional temporary Medicare billing privileges via telephone. Our hotline staff will collect information to establish a Provider Enrollment Chain and Ownership System (PECOS) enrollment record during the phone call,” the MAC says on its website.“Our staff will also be available to address questions regarding these temporary provider enrollment flexibilities afforded by the COVID-19 waiver.” Other MACs have also announced such a hotline.

It’s not a totally free pass, though.“If you have an [HHS Office of Inspector General] exclusion, your application will be rejected,” Palmetto says on its website.And “if you have a current adverse action on your license, we will consult with CMS to determine if the billing privileges will be granted.”

For all providers, including home care providers, CMS is waiving enrollment application fees, criminal background checks, and site visits; expediting pending or new applications; and postponing all revalidations, CMS says in a frequently asked question set on the enrollment changes.

See the FAQs at www.cms.gov/files/document/provider-enrollment-relief-faqs-covid-19.pdf.

• PEPPER. The release of new PEPPER benchmarking reports for providers including hospices is postponed indefinitely.CMS “is taking measures to free up the attention of providers as they respond to the coronavirus (COVID-19) pandemic,” according to a release about the delayed reports that include data ending in the last quarter of 2019.

While the feds have handed down a number of regulatory relief measures, HHAs and hospices are hoping to see more help as the COVID-19 response ramps up. Industry reps say providers would like to see restoration of Request for Anticipated Payments; waiver of homebound requirements for the Medicare home health benefit; NPPs allowed to certify patients for home care and hospice; reimbursement for telehealth visits that could take the place of in-person visits; relaxed staff supervision requirements; increased access and funding for personal protective equipment; and more.