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News Roundup: January 13, 2017

CMS rules boost record demands for home health

Published by Health Data Management
Joseph Goedert
January 13, 2017

The Centers for Medicare and Medicaid Services has issued final rules governing home health agencies under Medicare and Medicaid that include a mix of manual and electronic informational and record-keeping provisions, along with several streamlining requirements that aid home health providers.

For instance, agencies are expected to give patients and caregivers written information about upcoming visits, medication instructions, treatments administered, instructions for specific care that a patient or caregiver performs, and the name and contact information of a home health agency clinical manager.

All patients have the right to receive their clinical information—in hard copy or electronic form—including the care plan and free of charge, with records available within four business days.

The new rules also require “an integrated communication system” to ensure patient needs are met, care coordination among providers is in place, and there is active communication between an agency and a patient’s physicians.

Further, CMS is requiring home health agencies to have “a data-driven, agency-wide quality assessment and performance improvement program that continually evaluates and improves agency care for all patients at all times.” Standard infection controls also are mandated.

Mindful of the varied level of health information technology capabilities among home health agencies, CMS is allowing electronic signatures for record authentication, but did not accept requests that providers maintaining clinical records electronically can scan signature documents and then destroy paper copies.

“While we understand that home health agencies may desire to destroy paper copies of signature documents in order to reduce physical storage space, we believe that maintaining the original, signed paper documents is essential for purposes of authentication of the documents,” CMS noted in the final rules.

While CMS agreed that electronic audit trails may be useful for some agencies, they should not be a minimum requirement for all agencies “because there is more than one way for a home health agency to achieve the goals accomplished by electronic audit trails.”

CMS also imposed a five-year period for retaining records but acknowledged that some agencies require a longer retention period. The final rule, to be published on January 13, is available here.

Home Health Sector Faces Short Deadline for Sweeping New Rule

Published by Home Health Care News
By Amy Baxter
January 13, 2017

The home health industry is about to be inundated with new regulations after a long-expected update of the Conditions of Participation (CoP) was released by the Centers for Medicare & Medicaid Services (CMS) Monday.

With the introduction of the final rule that defines what is needed to participate in the Medicare and Medicaid programs, home health agencies and industry groups are wading through numerous changes. With an effective date of July 13, 2017, agencies have roughly six months to comply. One area of concern is the implementation time, which is much shorter than what was requested by agencies and home health associations during the comment period.

“We asked for 12-18 months lead time,” Bill Dombi, vice president for law at the National Association for Home Care & Hospice (NAHC), told HHCN. “We are assessing whether the 6 months is sufficient, given the rule outcome.”

When the rule was introduced in proposal form at the end of 2014, industry associations, including NAHC and the Visiting Nurse Associations of America (VNAA), asked for more than a year after publication of the final rule for agencies to comply. VNAA also asked for a a one-year period during which CMS would not sanction home health providers that are not in full compliance. Now, with a short timeline, associations are prepping members on their new requirements.

“With the quick six-month implementation date, VNAA is working to ensure that our members are fully briefed and prepared to comply with the July 13th deadline,” Joy Cameron, vice president of public policy at VNAA, told HHCN.

Home health agencies agree that the six-month period may be too short.

“[A] six-month implementation date is too soon for such a dramatic change in the CoPs,” Ken Miller, clinical educator of New York-based Catholic Home Care, told HHCN.

Despite the short timeline, not all industry groups are bracing for burdensome changes.

“Given the very significant scope and nature of the changes, we hope CMS will exercise discretion and flexibility on enforcement for a reasonable period of time after July 13, 2017 in recognition of the need for significant structure, process and training changes that agencies will need to make to comply,” Teresa Lee, executive director at the Alliance for Home Health Quality and Innovation (AHHQI), told HHCN.

Positive Changes

In fact, AHHQI is generally supportive of the changes, which had not been updated in roughly two decades. The Alliance also noted that the final rule did take into account some of their comments from the proposal period in 2015.

“The Alliance supports the newly revised conditions of participation and the focus on patient-centered care, patient rights and value and outcomes-based care,” Lee said. “CMS’s final rule also incorporates several recommendations made by the Alliance.”

The final rule aims to change all conditions of participation and add several new ones, with the potential to cause additional administrative burdens and costs. One such area that association groups are looking into relates to organizational structure and additional communication requirements.

Fortunately, it appears that at least some concerns voiced by home health care groups have been heard in the final rule.

“We are please that CMS will permit HHAs to use any form of communication, including secure electronic communications, to facilitate patient knowledge and understanding of the care being delivered,” Lee told HHCN. “This is consistent with the Allaince’s recommendation to permit electronic transmission of the plan of care information to patients and allowing for the flexibility on the means one might use.”

One of the new CoPs mandates expanding care coordination between a patient’s physician with an “integrated communication system that ensures that patient needs are identified and addressed” and that care is coordinated across all disciplines, according to CMS. The expansion requires home health agencies are in “active communication” with the physician(s).

Introducing more regulations between physicians and home health agencies could prove to be tricky; regulations related to the Pre-Claim Review Demonstration (PCRD) that require documentation from a physician earlier in the claims process has been challenging for some participating agencies. The issue even became a focal point in CMS’ education outreach to improve PCRD affirmation rates.

Documentation Changes

Another major change in the final rule centers on documentation requirements. While home health agencies have already seen their documentation requirements change rapidly over the past few years, thanks to initiatives within the IMPACT Act and Pre-Claim Review Demonstration (PCRD).

Under the new CoPs, home health agencies are required to provide additional documentation to patients and caregivers, including written information about upcoming visits, medication instructions, treatments administered, instructions for care that the patient and caregivers perform, and the name and contact information of a home health agency clinical manager.

Agencies also have to provide comprehensive patients’ rights that clearly enumerate the rights of home health patients and steps to ensure the rights are assured at all times.

“Of particular interest for us are the patient rights changes, which could be a significant implementation and operational burden for home health agencies,” Dombi said. “In addition, we are focusing on the changes related to infection control and the discharge summary.”

However, the language related to patient rights appears to have softened from the initial proposal. Specifically, CMS clarified that home health agencies are not expected to provide this in writing in every language, the Alliance told HHCN.

Furthermore, there is a new requirement for a data-driven, agency-wide quality assessment and performance improvement (QAPI) program that evaluates and improves agency care for patients.

“I think the biggest challenge is the development and implementation of the QAPI regulations,” Miller told HHCN. “New conditions that will likely be costly and burdensome are the QAPI.”

While it remains to be seen which is the most costly new provision, there’s no doubt that the new CoPs come with a significant pricetag: an estimated $293.3 million in the first year, according to the final rule.

Home Health Group Takes Aim at New Congress

Published by Home Health Care News
By Amy Baxter
January 13, 2017

With a new Congress already in place on Capitol Hill and the incoming Trump administration set to assume its post in the next few weeks, home health care industry groups are looking to push forth familiar agendas.

On the docket of industry groups are several bills that would improve new regulations or put a stop to burdensome programs already in place, including the controversial Pre-Claim Review Demonstration (PCRD).

At the same time, the home health industry has braced itself for the finalized Conditions of Participation (CoP) rule, which were released late Monday.

The final rule revises the Conditions of Participation (CoP) that home health providers must meet to participate in Medicare and Medicaid. The proposed rule was released in late 2014 to modernize home health care regulations for the first time since 1989, according to Joy Cameron, vice president of public policy at the Visiting Nurse Association of America (VNAA), who briefed association members Monday on policy changes likely to come.

Many industry groups, including VNAA and the National Association for Home Care & Hospice (NAHC), said changes to the conditions were needed, though they voiced concerns at the time on several proposals.

Legislation on Deck

As the industry wades through its new CoPs in the final rule, VNAA and other groups are still charging ahead by reintroducing legislation to the new Congress. Specifically, VNAA is hoping to get the Pre-Claim Undermines Seniors’ Health (PUSH) Act back into focus.

The bill was introduced to Congress by Representative Tom Price (R-GA-6), who has since been chosen as President-elect Trump’s pick for Secretary of the Department of Health and Human Services (HHS). The bill would put a one-year moratorium on PCRD, which is set to roll out in its second state, Florida, beginning April 1, 2017.

With Price moving on to a new post, VNAA is seeking its next sponsors of the PUSH Act, Nathan Constable, director of legislative affairs, told members of the organization’s plans.

Other aims of VNAA include policy to improve home health documentation, hospice training and the Home Health Planning and Priority Act.

“We made great strides on these [bills], beefed up co-sponsors, and have been able to get hearings, get agreements on legislative language for face-to-face [requirements],” Constable said. “Unfortunately, all bills must be reintroduced in the new Congress.”

Beyond legislation, the organization is keeping close watch on the potential repeal of the Affordable Care Act (ACA), which Republican members of Congress have already started to move on. President-elect Trump’s promise of changing the Medicaid financial structure is also on the table and could impact home health agencies.

At this point, however, most of the health care industry is in a wait-and-see mode.

Study: Registered Nurses Vital to Home Care Technology Success

Published by Home Health Care News
By Alana Stramowski
January 13, 2017

Technology is transforming the home care industry, but it hasn’t been easy to prove exactly how certain technology like telehealth and remote monitoring will help patient outcomes. However, there are now solid, research-backed tactics home care agencies can implement to increase positive health outcomes.

To see positive impacts of technology, home care companies need to focus on supporting and training their registered nurses as well as realizing that technology should not replace all human contact, according to a report released Wednesday from the University of California San Francisco.

The report, supported by the Health Resources and Services Administration (HRSA) of the U.S. Department of Health and Human Services (HHS), studied the use of electronic remote monitoring technologies and telehealth services of organizations for patients receiving long-term in-home care as well as those with chronic conditions such as obstructive pulmonary disease and kidney disease.

Focus on nurses

When it comes to ensuring positive outcomes from new technologies, training all workers who are caring for patients is important, but the primary health professionals involved in remote monitoring programs are nurses, Aubri Kottek, MPH, author of the report and research analyst at the Phil R. Lee Institute for Health Policy Studies at the Healthforce Center at the University of California San Francisco, told Home Health Care News.

“Predominantly nurses are the ones using the data from the telehealth or remote technology so this speaks to some of the training requirements that we need to make sure new graduates are equipped with,” she said.

Though health professionals like licensed practical nurses, medical assistants and community health workers could review the data first to check for red flags, nurses or mid-level providers are most often doing follow-up care, the report points out.

This also means agencies should focus more intensive training on nurses.

“The RNs’ scope of practice allows them the independence to utilize assessment skills while simultaneously following well-defined policies and procedures to communicate and act upon data,” the report says.

Tech can’t fix everything

Even though technology is where the health system wants to go, due to increasing the bottom line, it still cannot replace the human connection made between a nurse and patient, Kottek said.

“The findings are clear in the literature that people don’t want telehealth to replace human contact, they want to augment it,” a principal investigator who studied the aging process and health technology, said in the report. “We need to be cognizant that we don’t replace contact or home visits. When you walk in a home you’ll see a fall hazard you won’t see in a video conference.”

If home care providers can find a healthy balance of remote technology and human connection it will not only help the patients thrive, but improve the overall success of the provider, Kottek explained.

“I heard from several people during my research for the report say they’ve seen improvements in readmissions rates or have see how they can save money using telehealth or remote monitoring,” she said. “There’s the potential to do that if the program is developed mindfully and if you take into account the workflow and how efficient the program could be.”

See the full report from UCSF.