A Meaningful Relief for HHA in the Wake of a Pandemic
To make sure that the nation’s healthcare systems including hospitals and Home Health Agencies have the capacity to handle the possibility of a surge of COVID-19 patients, the Centers for Medicare & Medicaid Services (CMS) offers a broad range of flexibilities and temporary waivers of obligations for HHA all across the country. A few of major implications of the new rules to Home Health Agencies (HHA) during the COVID-19 Public health Emergency (PHE) are as follows.
Medicare’s Homebound Status Requirement
The homebound definition now comprises of all beneficiaries whose physicians advise them to stay home due to suspected or confirmed COVID-19 diagnosis or whose current medical conditions make them more susceptible to contract the disease. Assuming a homebound beneficiary needs skilled health services, HHA can provide such services under Medicare Home Health benefit.
Non-Fraud Related Claims Reviews
Claims with dates of service during the COVID-19 PHE (starting January 27, 2020 until expiration) will not be reviewed by CMS for compliance with appropriate signature requirements. The waiver only applies to non-fraud related claims including non-emergency ambulance transports. To be eligible for the waiver, ambulance providers and suppliers must indicate in the claim documentation that obtaining the required signature is not possible due to COVID-19. In the event potential fraud is indicated, CMS may conduct reviews during or after the PHE.
Home Health Remote Patient Assessments
HHAs are allowed to both perform initial assessments and determine beneficiaries’ homebound status (in accordance to the new regulation) either by record review or remotely. This waiver for HHA means the nation’s healthcare system can conduct better infection control, reduce the impact on long-term care facilities, and at the same time ensure that patients are cared for in the best possible environment during the pandemic.
Nurse Supervision of the Home Health Aide for Home Health and Hospice
CMS is waiving the requirement where a nurse or other professionals must conduct an onsite visit every two-weeks to evaluate if home health aides are providing care consistent with care plan. For the HHAs, supervision requirement by a registered nurse is also temporarily suspended, but virtual supervision is encouraged during the PHE or as long as the waiver is being implemented.
Encouraged Use of Medicare-Funded Telehealth Services
CMS encourages HHA to use telehealth to potentially reduce cost. However, all services that fall under telehealth paradigm must be physician-ordered rather than HHA choosing to exercise the method when onsite visit is ordered. In other words, HHA can provide telehealth services to reduce cost as long as it does not replace onsite visits as ordered on the care plan.
Review Choice Demonstration
During the duration of COVID-19 PHE, CMS gives the option for Home Health Services to continue or pause their participation. HHAs do not have to do anything for the pause to take effect.
Comments