Newsletter – April 2018
QAPI/Performance Improvement Project
Now that your agency has its QAPI program in place. Are you ready for the Performance Improvement Project that starts on July 13, 2018 and lasts Until July 13, 2019? Each agency should have an area where the overall quality of care and services provided will benefit through improvement measures, and create a project to carry out over a 12-month course with a structured plan toward that improvement goal.
The project needs to reflect the scope, complexity, and past performance of the agency’s services and operations. The agency needs to document the quality improvement projects undertaken, the reasons for conducting these projects, and the measurable progress achieved on these projects. This is a CMS mandated rollout as part of the new Conditions of Participation (CoPs) that went into effect on January 13th, 2018.
Agencies starting out or hiring new Administrator and or Director of Nursing staff members (including alternates) should be aware that the updated CoP requirements mandate that these staff members have at least 1 year of experience in Nursing, preferably in a home care setting, as well as a current RN level Nursing license at minimum to fill each of these positions. This represents a significant change from the previous Conditions of Participation (CoPs), which only required that the Administrator had supervisory experience, with no license requirements. Existing agencies with Administrators in these roles are exempt from the change until such a time that the Administrator resigns or is terminated. Any subsequent candidate for the position would need to meet these newly established requirements. This does not actually represent a change in requirements for the DON staff at all.
Additionally, alternate/backup staff roles are no longer able to be filled by the Administrator or Director of Nursing. All new startup agencies are required to have a separate staff member in each of these 4 roles (DON, backup DON, Administrator, backup Administrator).
Medical Home Health News
Home Health Agencies
The MassHealth moratorium affecting Home Health Service providers has been granted an additional 6-month extension by CMS, continuing to cite the growth in home health spending, and the number of new providers in the Commonwealth as risks to the integrity of the system, with the continued absence of a regulatory license process. This means that any Home Health Services provider that was not enrolled as a provider with MassHealth prior to February 11th, 2016 will not be able to become a provider for the network. This moratorium applies to MassHealth Waiver program enrollment as well. CMS Medicare continues to certify new providers in the Commonwealth with no changes to that process. The moratorium will be revisited by MassHealth on August 11, 2018 to determine its necessity to continue in place.
Adult Foster Care Program (AFC)
The MassHealth moratorium affecting Adult Foster Care providers has also been granted an additional 6-month extension by CMS. MassHealth has cited the existence of 100 operational AFC providers as being sufficient for the MassHealth eligible population in the Commonwealth. This means that any AFC provider that was not enrolled as a provider with MassHealth prior to April 1st, 2017 will not be able to become a provider for the network. The moratorium will be revisited by MassHealth on October 1st, 2018 to determine its necessity to continue in place.
MassHealth intends to continue its unannounced audits of approximately 5 providers per month across all LTSS providers, to include existing AFC, GAFC, and MassHealth Home Health Service providers. These audits are another ongoing measure to ensure quality, and prevent wasteful spending alongside prior authorizations, and rolling out the ACO structure to the Commonwealth. While some agencies will be selected at random for audits, most audits are generated based on MassHealth analysis of utilization and billing patterns.
Beginning January 1st, 2019 CMS will be adopting the newest version of the OASIS program, OASIS – D to replace OASIS C-1. Several new elements are being added to this update, as well as some wording changes. The new elements include:
- Revised Coding
- Patient Independence Ratings
- 6 Point Assessment Scale
And much more. Later in the year there will be a training announced in preparation for the launch.
CHAP Self Studies
CHAP Accreditation Self Studies have seen a substantial revamp as a result of the new Conditions of Participation (CoPs). Any agency that had previously completed CHAP Self Studies but not completed the CHAP Accreditation process before January 13th 2018, will need to complete Self Studies again using the newest version in order to continue forward with the Accreditation process. Any clients with questions regarding the Self Studies should reach out to Starsha McGillicuddy with our clinical department at 603-508-6172 ext. 101.
ACHC, our preferred Accreditation partner for Home Hospice agencies (www.achc.org) will be making minor changes to their Accreditation requirements, mainly focusing on personnel and other in-office areas, in June of 2018. Keep an eye out for the full list of updates.
Please be sure that you understand your Emergency Preparedness Plan (EPP), Quality Assurance (QA) program, as well as the process and requirements involved in hiring of qualified personnel.