This is a weekly digest of new information as well as briefs that may have already been provided to home and community-based organizations via e-mail alert throughout the past week.
State Announces Focused Off-Site Home Care Surveys Eyeing Infection Control
In a notice circulated late Friday, May 1, the state Department of Health (DOH) Division of Home and Community Based Services announced it will be conducting focused off-site surveys of some Certified Home Health Agencies and Licensed Home Care Services Agencies related to COVID-19 infection control policies and procedures. A select group of home care agencies in the Metropolitan Area Regional Office (MARO) area will be identified for the survey, the notice says.
Selected agencies will first receive a call from a surveyor and told to watch for the survey. They will be asked to submit certain documentation to the survey staff. The survey is composed of four questions and includes reference citations for guidance pertaining to operations during the pandemic.
Revised Telehealth Guidance and Webinar
DOH has released updated guidance for Medicaid providers regarding the use of telehealth and telephonic services during the COVID-19 state of emergency. DOH will also be holding a webinar tomorrow, May 5, with related information (from 10:30 a.m. to noon). Registration is here.
The revised guidance and updated Frequently Asked Questions document are available here.
The changes include:
- Clarification regarding payment parity for telehealth and telephonic services
- Additional billing and coding instructions, including Place of Service (POS) and Modifier codes to use in each of the telephonic billing lanes
- Billing rules for Article 28 services with a Professional Component
- Requirements for Medicaid Managed Care Plans
New Federal Waivers
As reported in an alert to HCA members on Thursday, CMS issued some additional blanket regulatory waivers. Among them are expanded telehealth permissions. However these do not provide direct relief for home care providers who still are unable to bill Medicare for telehealth or use it in place of visits. (HCA is working with the National Association for Home Care and Hospice, HCA members and other groups to resolve this obstacle while advocating for additional needed supports at the federal level.)
Rather, the new regulatory flexibilities now allow telehealth use by some additional professionals who may be employed in home care — i.e., physical therapists, occupational therapists, speech language pathologists — but still not for use under the Medicare home health benefit.
Other new regulatory changes include postponement of the 12-hour annual in-service training requirement for home health aides; waivers of certain discharge planning information requirements that include the coordination of information about post-acute care receiving organizations; extended deadlines for agencies to provide patients with copies of their medical records; waiving the home health and hospice requirements related to annual onsite supervisory visits; a narrower scope of Quality Assurance and Performance Improvement (QAPI) program requirements in home care and hospice; as well as postponing the requirement that hospices annually assess the skills and competence of all individuals furnishing care and provide in-service training and education programs.
HCA will be working with the state Department of Health to implement these changes.
HCA Receives Grants for COVID-19 Initiatives
HCA is launching two major statewide home care initiatives to address critical needs in the COVID-19 emergency — and beyond — thanks to a generous grant from the Mother Cabrini Foundation. HCA was informed of both project grant approvals late last week. One grant will fund a project to train home care agencies to conduct COVID-19 testing in partnership with the Iroquois Healthcare Association (IHA) and Mohawk Valley Health System (MVHS). Another will make available Self-help Community Services’ Virtual Senior Center (VSC) to all home care agencies in the state. To learn more, read our separate story here.
HCA Joins 1199 Multi-Organization Letter Urging Worker, Provider Funds
HCA and dozens of home care organizations, including several HCA provider members, have joined forces in signing a still-draft letter being circulated by 1199SEIU urging Congress to provide vital COVID-19 funding supports.
Among the groups’ requests are funds for home care workers and for home care provider reimbursements.
The letter, as now fashioned, is being addressed to leaders of the U.S. Senate and U.S. House and will likely be finalized this week, at which point HCA will share it with the membership.
HCA Seeks Clarification on State Recognition of NPP Authorizations
While CMS is opening up permanent authorities for certain non-physician practitioners (NPPs) to order home health services federally, HCA is seeking clarification on whether the state is likewise following suit with overlapping authorizations, including whether the state will permit all three of the CMS-recognized NPP disciplines to issue orders: nurse practitioners, physician assistants and clinical nurse specialists. HCA is soon expecting a Dear Administrator Letter or other state guidance in response to our call for clarification and confirmation from the state.
Application Open for Round III of NYC-Furnished PPE at HCA Member Pickup Sites
As announced in a member alert on Thursday, another round of personal protective equipment (PPE) dedicated for New York City home care providers is coming available soon, as furnished by New York City’s Department of Health and Mental Hygiene at designated sites hosted by HCA members.
To be eligible for this upcoming allotment, you must complete the form here. The deadline to do so is today, May 4, at noon.
From there, your agency will be contacted, if eligible, with further instructions on PPE pickup procedures at one of the distribution sites being hosted by HCA members.
We stress that this limited supply from the city is intended to supplement and not replace your PPE acquisition needs. Providers are encouraged to continue seeking reliable distributors to arrange for PPE.
For questions, please contact Ms. Billi Wilson at firstname.lastname@example.org.
PPE Supplier List
The Nassau County Department of Health Office of Emergency Management recently shared with HCA a list of PPE suppliers it has identified. A link with more information is shared on HCA’s COVID-19 resource page here.
May 5 Home Health and Hospice COVID-19 Call
On May 5, CMS is holding a call with targeted updates on the latest COVID-19 guidance. Conference lines are limited. Participants can join the audio webcast here or call 833-614-0820 using the access passcode 7844154.
OSHA Guidance on Respirator Decontamination
The Occupational Safety & Health Administration (OSHA) has released interim guidance on decontamination of respirators in health care.
This is the latest in a series of enforcement memos OSHA issued to address workplace exposure to coronavirus. Home health and hospice providers should review this information along with information from the U.S. Centers for Disease Control and Prevention (CDC) on Decontamination and Reuse of Filtering Facepiece Respirators.
EEOC Addresses Reopening Workplaces, Testing Employees
The U.S. Equal Employment Opportunity Commission (EEOC) has updated its COVID-19 guidance to address reopening of the workplace and testing employees for COVID-19.
Some of the topics include: confidentiality of medical information; hiring and onboarding; reasonable accommodation; furloughs and layoffs; and return to work.
Medicare Managed Care Survey Prioritization
CMS recently issued guidance announcing that it is prioritizing and suspending non-emergency federal and State Survey Agency surveys to allow surveyors and facilities to focus on protecting individuals from the spread of infectious disease, including the recent spread of COVID-19.
Consistent with that action, CMS is reprioritizing the audit activity for Medicare Advantage managed care organizations, Medicare Part D sponsors, Medicare-Medicaid Plans, and PACE organizations in order to allow CMS and these organizations to focus on health and safety threats.
OCR Update on HIPAA and COVID-19
The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) hosted an April 24 webinar for health IT stakeholders on HIPAA privacy and security issues as well as recent OCR actions related to COVID-19.
- COVID-19 and Permissible Disclosures under the HIPAA Privacy Rule
- Enforcement Discretion and Guidance for Telehealth Remote Communications
- Guidance for Disclosures to First Responders and Public Health Authorities
- Enforcement Discretion for Business Associates to Use and Disclose Protected Health Information (PHI) for Public Health and Health Oversight Activities
- Enforcement Discretion for Community-Based Testing Sites
CPR Guidelines: Taking into Account COVID-19
Until now, American Heart Association (AHA) CPR guidelines have not addressed the challenges of providing resuscitation in the context of COVID-19, as rescuers must continuously balance the immediate needs of the victims with their own safety. AHA and various medical groups have worked together on an interim guidance to that end. More information is here.
CDC Guidance on Post-COVID-19 Return to Work
The CDC has revised its criteria for health care workers to return to work. The guidance, “Criteria for Return to Work for Healthcare Personnel with Confirmed or Suspected COVID-19 (Interim Guidance),” is available here.
The state Department of Health has posted a Health Advisory on COVID-19 Serology Testing here.
Serology tests are used to determine if antibodies against SARS-CoV-2 are present. Certain serology tests can look for the general presence of SARS-CoV-2 antibodies, while others can determine if specific types of SARS-CoV-2 antibodies, such as IgM and/or IgG, are present. The guidance discusses U.S. Food and Drug Administration approval; state Education Department requirements for testing; state testing protocols; and more.