Newsletter – April 2019
Spring 2019 Edition
CMS Moratoria Lifted!
The Path has been Cleared for New HHA Startups in Huge Markets
The frustration was understandable for HHA license hopefuls across some of the nation’s largest markets including Dade County FL and Cook County IL; the licensure programs had been placed on statewide moratorium in August of 2016 and information on when they would be reopened was hard to come by. All that changed on January 30th when CMS announced the expiration of the Medicare Provider Enrollment Moratoria everywhere across the United States and it’s territories, opening the door for new agencies to begin servicing markets all across Florida, Illinois, Michigan, and Texas. The future looks bright as NAHC has assessed the near-term risk of a new moratorium as “remote at most”, however they do still suggest that startup hopefuls move quickly to submit applications and stay diligent in tracking their progress on advancing the certification process. This release does not affect ongoing state implemented moratoria on state Medicaid and agency license issuance in locations such as North Carolina(In-Home Health Aide Services Moratorium), or New York(LHCSA License Moratorium); covered in more detail on the next page under Medical Home Health News. For more information on how the lifting of these moratoria might affect your existing agency or how you can take advantage of these openings with a new agency, reach out to one of our certified consultants today!
Emergency Preparedness Standards Revisions
The Centers for Medicare & Medicaid Studies (CMS) have also announced new updated interpretations for the Emergency Preparedness Standards in the first quarter of 2019. These revisions to the interpretations address disasters – facility-based, natural and man-made, requiring that agencies take on an “all hazards” approach, so as not to focus exclusively on the potential of a particular disaster while losing sight of the potential crises created locally within a facility or patient home as a result of the larger emergency event. As an example, addressing an emergency based on a regional storm having knocked out power, which in turn potentially causes life-saving/sustaining equipment failure, communication failure and a breakdown in provision of direct care services, are all emergency events within an emergency that need to be addressed directly in emergency planning. EIDs (Emerging Infectious Diseases) and the necessary containment or exposure risks are factors that need to be addressed directly in the planning as well.
Drill frequency is also clarified in this latest round of interpretations. In the event of multiple disasters in one year, Home Health agencies would be exempt from having to comply with the performance minimum of 2 emergency drills in the same year. The following year, the drill requirement would resume their normal frequency in the absence of multiple events requiring Emergency Plan activation. Additionally, in the event of only one emergency event in a year, the second desktop review would still be required to be performed.
Medical Home Health News
Massachusetts 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 licensing 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 continues to certify new Medicare providers in the Commonwealth with no changes to that process. The moratorium will be revisited by MassHealth on August 10th, 2019 to determine its necessity to continue in place.
New York Home Care Service Agency Licensure
The New York State Department of Health announced a moratorium to be enacted April 1st, 2018 on the processing and approval of LCHSA (Licensed Home Care Services Agencies) licenses that is set to continue in place for two years, expiring on March 31st, 2020. Exceptions to this moratorium include Determinations of Need, purchase and sale transfers of ownership, and Assisted Living Program licensures.
North Carolina Moratorium on Home Health Aide Services
The North Carolina Division of Health Service Regulations (NC DHSR) has elected to extend their moratorium on issuing licenses for agencies that intend to offer In-Home Aide Services until June 30th, 2019 at which time the moratorium shall be reviewed to determine it’s continued necessity. This moratorium applies to new licensure for both Home Care (personal care) agencies as well as Skilled Service Home Health Agencies.
An item of note, there are consultants that are offering services to assist in setting up Nurse’s Aide staffing registries as a workaround to this measure from the state. Nancy Joyce, Administrative Officer at NC DHSR has stated this process to be highly unethical, and while the state’s resources were limited at the time or our discussion, they are actively prosecuting individuals that attempt to circumvent the regulation through this method. At Certified Homecare Consulting, we value greatly our working relationships with state regulatory bodies and pride ourselves on the integrity exercised in consulting with our clients to achieve startup agencies that comply with national and state regulation at all times.
Adult Foster Care Program (AFC), Shared Living and PCA/PCM
The MassHealth moratorium affecting Adult Foster Care providers has been granted an additional 6-month extension by CMS. MassHealth has additionally added it’s Shared Living, and PCA/PCM programs to this moratorium. This means that any AFC, or PCA/PCM 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, 2019 to determine its necessity to continue in place.
Beginning January 1st, 2020 CMS will be adopting the newest version of the OASIS program, OASIS – D1 to replace OASIS D based on proposals that were finalized in the 2019 Home Health Final Rule CMS 1689-FC. Several new elements are being added to this update, as well as some wording revisions. The new elements cover:
- Two additional items added to the Follow Up assessment (along with correlating revisions to the All Items assessment)
- Risk for Hospitalization
- Changes to 23 items from required data collection to optional data collection covering:
- Start of Care/Resumption of Care (SOC/ROC)
- Transfer and Discharge
For more details and orientation, call today to find out about ongoing training sessions.
Behavioral Health Services Help to Combat Opioid Crisis
It is no guarded secret that America is undergoing a serious crisis related to the misuse of prescription painkillers and other opioid substances. Of the 64,000 drug overdose deaths recorded in 2016, 40% were related to a prescription opioid and 4 out of every 5 heroin users got their start on a prescription first, according to the CDC. With so much negative news coming in every day it can be easy to feel defeated by the crisis but it is not a lost cause! This year Home Health conglomerate Elara Caring put forth some positive news on how Home Health Agencies of all sizes can help their communities combat the ongoing crisis: Behavioral Health Services. About 40% of Elara Caring’s Behavioral Health patients are being seen for issues related to drug dependency according to a recent article put out by Home Health Care News, and the convenience of at-home care is making a real difference in patients’ lives across the country. Services like acute psychiatric intervention, crisis stabilization, medication management, community stabilization, family interventions, crisis prevention and management for the long-term chronic mentally ill consumers all fall under the umbrella of Behavioral Health and can all help to turn the tide in the fight against opioid addiction and abuse. A Behavioral Health Policy is a great way to supplement the medical home care services you already offer and opens the door to a whole new market or potential clients. To find out more about how you can add Behavioral Health Services to your Home Health Care repertoire and begin servicing your local community reach out to one of our knowledgable consultants today!
New Jersey Accreditation Deadline Imminent
All New Jersey Non Medical Home Care Agencies should already be aware that the deadline for state certification in 2019 is fast approaching. All agencies should have an up-to-date state certification by Friday, May-17th, 2019, and both CAHC and ACHC are now equipped to assist in this process. Is your agency’s accreditation up to date? If you have any questions or concerns about your standing dont hesitate, reach out today to one of our certified consultants for expert advice you can trust.
Group Adult Foster Care (GAFC)
While no moratorium for this program has been announced and both the GAFC program director, Allison Ananis, and the director of Long Term Services and Supports (LTSS), Whitney Moyer, have been emphatic in their assurances that the program is not going into moratorium, all agency applications have been on hold since mid-June of 2018 as the program undergoes revisions to it’s enrollment process. Neither department has been able to provide a timeline as to the completion of these revisions, and the resumption of the enrollment processing. Our consultants are staying abreast of the situation as conditions change and program hopefuls can rest assured that work will resume on theirs’ and other new GAFC processes as soon as the program continues for application processing.
Medicare Advantage Reimbursement
What is it and how does it affect MY Non Medical Home Care Agency?
Originally developed in the 1970s as a way for Medicare beneficiaries to receive their benefits through a personal insurer, the changes implemented to the Medicare Advantage Program by the Trump Administration in October of 2018 are further expanding the scope of services providers can bill. Some Non Medical Services that were previously off limits, like Personal Care and Daily Living Services for some qualifying patients, can now be billed through personal insurers who will then recieve reimbursement from the Medicare Private Health Plan pool, also known as Medicare Advantage.
In the year 2000 only about 15% of Medicare enrolees received their benefits through a Medicare Private Health Plan; by the year 2017 that number had moved to 33% and with the incorporation of the new Non Medical Assisted Daily Living Services that percentage is looking to grow even more.
While Blue Cross Blue Shield and Amerigroup are the only insurers who have adapted to the new statutes so far, with time and the sucess of the program many more insurers will likely follow suit.
So what does this mean for your Non Medical business? In short, a huge new market of clients just got insured access to the services that you already provide. While the situation remains fluid and much will likely change from now to the full adoption of the plan by more insurers, here is a sneak preview of some of the services being covered:
- Up to 16 home delivered "healthy" meals per health event, or no more than 64 meals per year. A qualifying health event may be a hospital discharge, or if a member is very overweight or has severe uncontrolled diabetes.
- Up to 60 one-way trips per year to health-related appointments or other covered services.
- Up to 124 hours of support from a home health aide or similar assistance.
- A $500 allowance for safety devices such as shower stools, reaching devices, or temporary wheelchair ramps.
- Up to 1 visit per week for adult day services.
- Up to 24 acupuncture and/or therapeutic massage visits
These benefits currently vary based on region, and will surely continue to be refined as real-time implementation provides crucial data toward what variations to future offerings might best serve seniors opting for these plans, as well as what works best for insurance and care providers in rolling out these services.
These changes in Medicare Advantage Plan benefits represent a massive opportunity for Non Medical home care agencies. The support hours provided in the 2019 plans alone represent approximately $2,000 per patient newly available to these agencies. For more information on what the future may hold for these exciting new programs and how your agency may be uniquely suited to take advantage of them reach out to one of our certified consultants today!
Patient Driven Grouping Models
Scheduled to begin January 1st-2020, the Patient-Driven Groupings Model (PDGM) is a new payment model for the Home Health Prospective Payment System. This new payment model will rely more heavily on clinical characteristics and patient data to classify home health periods of care into payment categories.
PDGM will eliminate the use of therapy thresholds and separate payments for medical supplies. PDGM will require home health agencies to take a close look at their daily operations, including clinical documentation, coding, and especially billing. Billing will now occur every 30 days within a 60- day episode. At the moment it is only scheduled to affect Medicare reimbursement but additional payors may eventually adopt the model.
At Certified Homecare Consulting we know first hand that it pays to be ahead of the curve, that’s why we strive to keep your agency informed of changes to regulation that will affect your business. If you have any specific questions about how the change to PDGM will affect your agency reach out to our clinical department today.