Home Health & Hospice Week

Pay attention to the makeups you’ll need to do when the PHE lifts.

Medicare is trying to provide home health and hospice agencies with even more flexibilities to help them fight COVID-19. But you might not want to take the program upon every waiver it offers.

For example: The Centers for Medicare & Medicaid Services is modifying requirements for both provider types to “develop, implement, evaluate, and maintain an effective, ongoing, hospice/ HHA-wide, data-driven [Quality Assurance and Performance Improvement] program,” CMS says in new waivers released April 30.“Specifically, CMS is modifying the requirements … to narrow the scope of the QAPI program to concentrate on infection control issues, while retaining the requirement that remaining activities should continue to focus on adverse events.”

CMS has made the change because “this modification decreases burden associated with the development and maintenance of a broad-based QAPI program, allowing the providers to focus efforts on aspects of care delivery most closely associated with COVID-19 and tracking adverse events during the PHE,” according to CMS’ updated “Home Health Agencies: CMS Flexibilities to Fight COVID-19” document.

But the waiver doesn’t mean QAPI goes away, CMS points out.“The requirement that HHAs and hospices maintain an effective, ongoing, agency-wide, data-driven quality assessment and performance improvement program will remain,” the document stresses.

“With this QAPI waiver, agencies can focus on the infection control and adverse event portions of their QAPI programs,” says Sharon Litwin with 5 Star Consultants in Camdenton, Missouri. But agencies still may want to keep other quality indicators too, Litwin suggests.

For example, if agencies have indicators such as IV services, physician notification, and wound care, Litwin suggests they continue with them. Such indicators “remain so critical to a patient’s health and safety,” she notes.

Annual Visit, In-Services Postponed

CMS addresses aide requirements in two new waivers. In its first round of waivers, the agency waived the requirements for a nurse or other profes­sional to conduct an onsite visit every two weeks to evaluate whether aides are providing care consistent with the care plan.

First: Now for both provider types, CMS is waiving the requirement for a registered nurse or, for HHAs, other professional “to make an annual onsite supervisory visit (direct observation) for each aide that provides services on behalf of the agency,” the flexibilities document says. Once the PHE expires, agencies will have 60 days to complete all postponed onsite assessments.

“Since there should be the minimal number of staff in a patient’s home during the PHE, having the RN onsite with the aide for an annual supervisory visit would not be appropriate,” Litwin says. Instead, “the RN can meet with the aide in the agency during the PHE and review aide services, the aide care plan, etc., rather than going onsite,” Litwin suggests. Then agencies must make sure “to do all annual onsite visits with the aides within 60 days of the PHE being lifted,” she stresses.

Second: CMS also is modifying the requirement that HHAs must ensure that each home health aide receives 12 hours of in-service training in a 12-month period.“We are postponing the deadline for completing this requirement throughout the COVID-19 PHE until the end of the first full quarter after the declaration of the PHE concludes. This will allow aides and the 2 registered nurses (RNs) who teach in-service training to spend more time delivering direct patient care and additional time for staff to complete this requirement,” according to the flexibilities document.

Other waivers in the second round address:

• Inpatient hospices. “CMS will permit facilities to adjust scheduled inspection, testing and maintenance (ITM) frequencies and activities for facility and medical equipment,” says a CMS flexibilities document for “Health Care Providers” in general.
• Hospice training. “CMS is modifying the requirement … to annually assess the skills and competence of all individuals furnishing care and provide in-service training and education programs where required,” the hospice flexibilities document says.“We are postponing the deadline for completing this requirement throughout the COVID-19 PHE until the end of the first full quarter after the declaration of the PHE concludes.” However, “this does not alter the minimum personnel requirements at 42 CFR §418.114. Selected hospice staff must complete training and have their competency evaluated in accordance with unwaived provisions of 42 CFR Part 418,” CMS says.v

Note: The general flexibilities document with the new waivers marked is at www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf. The updated HHA flexibilities document is at www.cms.gov/files/document/covid-home-health-agencies.pdf and the updated hospice flexibilities document is at www.cms.gov/files/document/covid-hospices.pdf.