COVID-19

Important note: when examining the resource links below, please be mindful of dates (wherever labelled) to ensure that you are reading the most recent guidance or update.  Please also be sure to refresh your browser to ensure that you are viewing the most current file, as information is being continuously updated.

HCA Vaccine Checklist

Vaccine Dispensing Sites and Appointment Links

Please encourage your staff to use the links below to make vaccine appointments. Please also use HCA’s vaccination readiness checklist to guide staff through the vaccination process. Also below we’ve included a table of county health department information with links to the counties’ public-facing websites where they’ve posted vaccine information.

Vaccine Education Resources and Information

Please utilize the following resources to communicate the effectiveness and the importance of the COVID-19 vaccine among staff and patients. Vaccine hesitancy is real. The following resources can help overcome it.

Other Vaccine Resources and Information

DOH Vaccine Website

New York State has launched a new website dedicated to COVID-19 vaccine information. It includes information about the vaccine, the state’s distribution plan, safety measures, the process for providers to order the vaccine, frequently asked questions, and more.

DOH has also posted the following additional resources:

  • A guidance document reminding and informing vaccine administrators of their obligations when reporting the New York State Immunization Information System and the City Immunization Registry.
  • Instructions on the newly developed COVID-19 Vaccine Form, which providers should encourage all patients to complete before receiving the vaccine.
  • A template COVID-19 Immunization Screening and Consent Form.
  • A screening checklist for health care providers.
  • Medicaid Reimbursement for Vaccine Administration: The state Department of Health (DOH) has posted guidance on New York’s Medicaid reimbursement policy for the administration of COVID-19 vaccines authorized for emergency use and instructions for providers to bill the cost of administration of authorized COVID-19 vaccine.  

NYS and NYC Vaccine Registries

HCA encourages members to enroll in the city or state immunization registries and vaccination enrollment programs. New York City providers should consult the following resources:

Providers outside of New York City should consult the following resources:

CDC Resources

COVID-19 Counseling and Emotional Support Helpline

Project Hope is New York’s COVID-19 Emotional Support Helpline.

NY Project Hope helps New Yorkers understand their reaction and emotions during the COVID-19 pandemic. Through an emotional support helpline, educational materials, and trusted referrals, NY Project Hope helps people manage and cope with changes brought on by COVID-19.

Emotional Support Helpline: 1-844-863-9314

PPE Supplies from NYC Stockpile

CHHAs and LHCSAs who provide home care services in New York City (NYC) and meet certain criteria are able to order personal protective equipment (PPE) from Medline, a company selected by NYC to provide PPE to health care providers. Providers must pre-register for this process. If you have not done so already, please write to PPEsupport@health.nyc.gov.

The NYC stockpile of PPE via Medline will act as a last-case, emergency option for providers after all other options have been exhausted. By submitting a request through medline.com, organizations confirm that the PPE is required to protect staff and patients during the COVID-19 response and that the agency currently has less than one week of the requested supplies on hand. Note: As of around December 7, 2020 this latter requirement was removed by NYC and providers need not have less than a week of supplies to make orders through this process.

A user guide on the submission process, along with Frequently Asked Questions, is here.

Questions about the Medline distribution process can be directed to the NYC customer service desk at 866-478-1490, ext. 2222.

Current Regulatory Waivers, Changes (Updated 07/30/21)

Below is a summary of regulatory waivers that have been established throughout the course of the federal and state emergency declaration. Now that New York Gov. Andrew Cuomo has lifted the state’s declared public heath emergency, effective June 23, 2021, HCA is working to determine the status of state emergency waivers, many of which may be ending. Please check all state guidance documents and other resources for updates.

Please also note that while some waivers may be issued at the federal level, this does not mean that the state has necessarily also recognized the same changes in parallel fashion. Providers should not rely strictly on the summaries below and should always read the source documents linked accordingly for further details, contingencies and context.

Federal

Medicare Home Health Telehealth Services: On March 30, 2020 CMS issued a very incremental allowance for home telehealth. Congress, in the recently enacted CARES Act for coronavirus relief, called upon federal officials to “encourage” telehealth. CMS has responded in a limited fashion, determining that the law does not permit CMS to pay home health agencies for telehealth. (The state Medicaid program, meanwhile, has already provided much more flexibility in this regard for Medicaid services, as reported below.) CMS is ostensibly allowing expanded telehealth as a means to reduce costs, but not as a service billable under Medicare.

Medicare “Homebound” Requirement: On March 30, 2020 CMS determined that an individual meets the requirement for “homebound” status if needing skilled services and if deemed by a physician at high risk of contracting COVID-19 due to a compromised health condition.

Medicare Home Health Conditions of Participation (CoPs) and NPP Certifications: CMS implemented language from the CARES Act permitting non-physician practitioners (nurse practitioners, physician assistants, and certified nurse specialists) to order and refer for Medicare home health services. (See a summary document from the National Association for Home Care and Hospice here.) Important: New York State has issued a proposed rule that would appear to allow broad NPP-ordering permissions but this rule has not been finalized or implemented at this time, leaving the status of NPP certifications uncertain for New York State providers.

Hospice Volunteers, Assessments, Non-Core Services, Supervision: Per the CARES Act, CMS announced on March 30, 2020 that it is 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.

Aide In-Service, On-site Supervisory Visits, QAPI and Furnishing Medical Records to Patients: On April 30, 2020 CMS announced several blanket waivers including 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.

*Important note: On October 13, 2020 the state Department of Health informed providers that its surveyors will exercise “enforcement discretion” when surveying providers for compliance with aide in-service requirements that have been waived by the federal government. In a July 23, 2021 Dear Administrator Letter, DOH said it will continue to exercise “enforcement discretion” when surveying providers for compliance with in-service training requirements for PCAs (3 hours on a semiannual basis) until December 31, 2021, and for HHAs (12 hours annually) until the end of the first full quarter following the declaration of the end of the federal Public Health Emergency (PHE). HCA advises agencies to exercise caution in relying on enforcement discretion by individual surveyors and to document all efforts to meet the requirements, as well as document any barriers to compliance.

State

Note: for the latest state regulatory statements, please see the state’s Home Care and Hospice Dear Administrator Letters posted here.

Medicaid Telehealth Use, Billing: A special edition of the state’s Medicaid Update on March 21 and updated on March 23, 2020 (see here) includes a guidance broadly expanding the use of telehealth, telephonic services, and other communications methods by Medicaid providers during the COVID-19 state of emergency. This guidance was followed up with an extensive frequently asked questions document issued on March 31, 2020 (see here). Effective for dates of service after March 1, and for the duration of the state of emergency, “New York State Medicaid will reimburse telephonic assessment, monitoring, and evaluation and management services provided to members in cases where face-to-face visits may not be recommended and it is appropriate for the member to be evaluated and managed by telephone.” HCA has confirmed with DOH officials that the guidance applies to Article 36 home care providers and the March 23, 2020 version of the guidance provides more specific home care service and billing codes. It adds: “All telephonic encounters documented as appropriate by the provider would be considered medically necessary for payment purposes in Medicaid fee for service or Medicaid Managed Care.” Update: on June 25, 2021, DOH issued a Comprehensive Guidance Regarding Use of Telehealth including Telephonic Services that extends telehealth service and billing allowances after the expiration of the state’s public health emergency declaration.

RN Supervision Visits Under Medicaid Personal Care: Governor’s Executive Order No. 202 “permit(s) nursing supervision visits for personal care services provided to individuals affected by the disaster emergency be made as soon as practicable” (emphasis added) in place of requirements for such visits to be made “at least every 90 days.”

Employee Health Assessments, Performance Evaluations, Aide Training: In an April 10, 2020 Dear Administrator Letter (see here) to CHHAs, LHCSAs, LTHHCPs, and Hospice programs, the state Department of Health has suspended or changed the following regulations.

Annual performance evaluations of current employees by home care agencies and programs are temporarily suspended.

The time in which a home care aide training program must be completed is extended to 90 days (HCA asked for 120 days).

The Alternate Competency Demonstration look-back period is expanded to 3 years, from 2 years, and the prospective employee must have 3 months of experience, rather than 6 months.

The time period is extended by which home health aide training programs must submit an intent to submit a class schedule to regional offices (April 1, 2020 to July 1, 2020).

New employees may have health assessments completed by telehealth or by an RN. New employees must follow guidelines in place for all staff, including daily symptom screenings and at least daily temperature checks.

All CHHAs, LTHHCPs, AIDS home care programs and LHCSAs serving individuals affected by the COVID-19 public health emergency may conduct in-home and in-person supervision through indirect means, including by telephone or video communication, as soon as is practicable after the initial visit. Update: As of July 30, 2021, DOH has indicated that agencies should begin resuming in-person assessments and visits as soon as practicable, noting that guidance regarding in-person assessments and aide supervision is forthcoming.

Supervised Practical Training: In an April 10, 2020 health advisory (see here), the state Department of Health waives the requirement that 8 hours of the 16 hours of supervised practical training must be provided in a patient care setting.

Opening Cases: All CHHA, LTHHCP, AIDS home care and LHCSA home care cases may be opened using remote technology (see the April 10, 2020 Dear Administrator Letter from the state Department of Health).

Medicaid Program Initial Service Visit, Home Care Registry, Supervision Visits, Fair Hearings: Governor’s Executive Order No. 202.5:

To the extent necessary to permit certified home health agencies, long term home health care programs, AIDS home care programs, and licensed home care services agencies serving individuals affected by the disaster emergency to conduct in-home supervision of home health aides and personal care aides as soon as practicable after the initial service visit, or to permit in-person and in-home supervision to be conducted through indirect means, including by telephone or video communication.

To the extent necessary to permit initial patient visits for certified home health agencies, long term home health care programs and AIDS home care programs serving individuals affected by the disaster emergency to be made within 48 hours of receipt and acceptance of a community referral or return home from institutional placement.

To the extent necessary to allow or require appearance by any parties to a fair hearing by written, telephonic, video or other electronic means.

State/Federal/Other

Medicare and Medicaid Face-to-Face Requirements: For clarification, below are the Medicare and Medicaid face-to-face (F2F) requirements including the extent to which telehealth or telephony are permissible or not.

Medicare: The physician F2F encounter can be performed via telehealth. Under the expansion of the telehealth waiver, beneficiaries can use telehealth modalities with their doctors and practitioners from home for the face-to-face encounter to qualify for Medicare hospice and home health care services. As of April 7, 2020, the telehealth mechanism must be two-way live video. The federal government has relaxed HIPAA enforcement so that commonly available platforms like Skype, Facetime and Zoom may be used for telehealth purposes.

Medicaid: The physician F2F encounter can be performed via telehealth including telephonic means. Medicaid Update, Volume 36 (on March 23, 2020) indicated that provider must be enrolled in the New York State Medicaid program. Physicians, nurse practitioners can complete the necessary F2F documentation

Key Home Care, Hospice and Managed Care Guidance or Resources

COVID-19 Specimen Collection and Testing

Guidance on Face Masks and PPE

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