HCA Continues to Press on PPE Needs, Prioritization
Severe shortages of personal protective equipment (PPE) continue to pose dangerous health and safety risks across all health care settings. A yet further constraint is the fact that the New York City Department of Health’s directives on supply prioritization have thus far categorically omitted home care and hospice.
HCA has raised these alarms repeatedly, in direct outreach to all levels of government and in the press.
Following a March 27 discussion with the Deputy Health Commissioner, HCA over this past weekend again urged the City Department of Health to amend its policy to properly include home care and hospice as a category in its list of settings deemed a priority for PPE.
In this latest communication (see here), HCA shared further information requested by the Deputy Health Commissioner regarding the specific PPE needs in home care and hospice to assist with current patient care as well as to support hospital decompression. We also cite HCA’s survey statistics on PPE shortages, home care and hospice procedures that require PPE for patient and staff safety, and some strategies for conservation and use.
Please stay tuned for further expected updates in the week to come.
DOH Emphasizes Instructions for PPE Requests through Local OEM
Meanwhile, state Department of Health (DOH) officials, noting the influx of individual PPE requests, have asked HCA to share the state’s guidance on obtaining PPE. This guidance includes submission of requests to the local Office of Emergency Management (EOM) first. (See the guidance here.)
If supplies are exhausted, providers are instructed to send a request via the county OEM to the New York State OEM with as much detail as possible (e.g., type and quantity of PPE by size, point of contact, delivery location, date needed, record of pending orders).
“We understand that agencies have reported difficulty reaching some county OEMs,” states a message to the provider associations from Carol Rodat, Director of the Division of Home and Community Based Services. “If that happens, please make sure that CHHAs and Hospices are completing the CHHA and Hospice surveys. If LHCSAs have been unable to obtain PPE, we can discuss a mechanism to capture the data in advance of the LHCSA survey; however, we will need to confirm that they have submitted a request to the local OEM.”
HCA Presses Additional Regulatory Relief at State Level
In outreach to state DOH officials last week, HCA cited nearly 20 areas of needed relief or regulatory waivers during the COVID-19 emergency. (See here.) Among these are waivers on aspects or specific circumstances involving: health screenings and annual health assessments, criminal history record checks, patient notification requirements, in-service and health aide training program requirements, physician order time periods, uniform assessment system assessments and service area expansions. We also urge the dissemination of “essential provider” instructions to law enforcement agencies emphasizing that home care is an essential business and to permit worker travel. In addition, we call for temporary parking placards to include home health aides working under Article 36 health law.
State DOH Guidance: Personnel Returning to Work and Medicaid Telehealth FAQs
The state DOH issued two new COVID-19 guidance documents in the prior week. One of these (dated March 31) replaces a prior guidance on protocols for personnel returning to work following COVID-19 exposure and infection (see here). The other is a frequently asked questions (FAQ) document on new Medicaid service and billing allowances through telehealth and telephonic means during the COVID-19 emergency (see here). The FAQs offer information on telehealth billing, who can provide telehealth services, and other items related to the new temporary emergency allowances applicable to Medicaid services.
CMS Waivers, Flexibilities on Homebound Status, Permanent NPP Authorizations and CoPs
The U.S. Centers for Medicare and Medicaid Services (CMS) has issued some new regulatory waivers and flexibilities, including a very incremental allowance for home telehealth and important latitude on the “homebound” requirement. This information is here. It follows prior implementation of allowances for non-physician practitioners (physician assistants and nurse practitioners) to order and refer for home health services — a change that we understand to be permanent under the CARES Act.
Additionally, CMS has waived home health Conditions of Participation (CoPs) related to onsite home health aide supervision and in-person initial patient assessments which can now be done remotely.
For a summary of all principal state and regulatory waivers, please see HCA’s COVID-19 resources page.
Federal Hospice Waivers and Flexibilities
Per the CARES Act, CMS is allowing use of telehealth for the physician face-to-face encounter requirement in hospice and permitting telehealth billing by hospice physicians. It is also waiving: the requirement for hospices to use volunteers; timeframes for updating comprehensive patient assessments; non-core services requirements; and the 14-day home health aide in-person supervisory requirements, consistent with home health waivers. It has also suspended all medical review audits other than in cases of fraud investigation.
NYC Guidance on Reuse of PPE
On March 31, 2020, the New York City Department of Health and Mental Hygiene distributed an Overview of Strategies for Reuse and Extended Use of Personal Protective Equipment (PPE) referring to the practice of using the same PPE for multiple encounters with patients but removing it (‘doffing’) between each of those encounters (see here).
“The equipment is safely stored in between patient encounters,” the guidance states. “Previously used PPE should never be taken outside of patient care areas unless the item is decontaminated or placed in a clean breathable container.” The guidance goes on to describe procedures specific to the various forms of PPE.
State Announces Emotional Support Helpline for Healthcare Workers
The New York State Office of Mental Health has announced a COVID-19 Emotional Support Helpline for health care workers and first responders to get help with anxiety, stress, depression, trauma, and grief. The helpline is available from 8 a.m. to 10 p.m. seven days a week at 1-844-863-9314. Please see the flyer here and share it with your clinical managers and aide supervisory teams.