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COVID-19: update waivers and delay of Oasis E

Link Healthcare Advantage and MatrixCare have teamed up to help give insight into what is happening within the industry and hopefully address some of those unanswered questions, that maybe you didn’t even know to ask.

CMS released more COVID-19 waivers and interim final rule that impact home health and hospice operations on April 30, 2020. The waivers provide flexibility to health care providers during the public health emergency (PHE) in an effort for agencies to focus on people rather than paperwork.

Home health

Please see the list of home health waivers issued by CMS and their description below.

  • Home health aide annual assessment – waives the timing requirement for an annual on-site supervision for each aide that provides services. Aides that were due for an annual on-site visit during this PHE will have up to sixty days after the expiration of the PHE to complete the on-site supervisory visit.
  • Home health aide annual in-service hours – the requirement for twelve hours of annual education has been extended to be completed by the end of the first full quarter after the PHE ends.
  • Discharge planning – waives the requirement to provide the patient, caregiver and/or patient representative quality measure data during the PHE.
  • QAPI – modifies the scope of the QAPI program to concentrate on infection control and adverse events. The requirement to maintain an agency-wide, data driven QAPI program remains the same.
  • Clinical records – extends the timeframe for providing patients with copies of their medical record on the next visit or up to four business days has been extended to ten business days.
  • VBP – new measures data submission for April 2020 submission (October 1 through March 31 2020) and July 2020 submission (April 1 to June 30, 2020) has been granted exception. CMS is evaluating possible changes to the payment methodologies for CY2022 in light of limited data collection.
  • OASIS E – implementation was postponed until January 2022.

Hospice

Please see the list of hospice waivers issued by CMS and their description below.

  • Hospice aide annual assessment – waives the timing requirement for an annual on-site supervision for each aide that provides services. Aides that were due for an annual on-site visit during this PHE will now have up to sixty days after the expiration of the PHE to complete the onsite supervisory visit.
  • All staff annual competency and training – postpones the hospice requirement for annual assessment of competency and in-service training requirement to be completed prior to the first full quarter after the PHE ends.
  • QAPI – modifies the scope of the QAPI program to concentrate on infection control and adverse events. The requirement to maintain an agency-wide, data driven QAPI program remains the same.

Inpatient hospices

Please see the list of inpatient hospice waivers issued by CMS and their description below.

  • Testing and maintenance physical environments – CMS has adjusted scheduled inspection, testing, and maintenance frequencies for medical and facility equipment.
  • Outside window and door requirement for each sleeping room has been waived to allow for flexibility in using facility space that is normally used for patient care for quarantine or temporary patient care area.

The following Life Safety Code and Health Care Facility Code adjustments testing are NOT waived

  • Sprinkler systems monthly
  • Portable fire extinguisher monthly
  • Elevators monthly
  • Emergency generator monthly
  • Daily inspection of egress areas under construction

Implementation tips

The following are some implementation tips from Link Healthcare Advantage:

  • Annual on-site assessments – agencies need to document and track all staff members that were due for an annual on-site assessment during the PHE and prepare an action plan to complete these within that sixty-day extension period.
  • In-service training and education – agencies need to continue with competency assessments as part of their orientation program.
  • QAPI – include in your QAPI plan your COVID-19 patient and staff infection tracking data along with documentation of items that your agency has implemented in response to the PHE. The requirement for at minimum one performance improvement project (PIP) continues and agencies may want to consider utilizing COVID-19 precautions as part of their PIP.

We hope this has helped your agency identify the latest COVID-19 waivers and CMS changes.

Learn more about how MatrixCare Home Health & Hospice is supporting providers through COVID-19 and beyond.

Disclaimer: we are not endorsing this information for accuracy or validity of the content. We encourage you as appropriate, to verify clinical and regulatory content with your own trusted sources.

Sources:

https://www.cms.gov/files/document/summary-covid-19-emergency-declaration-waivers.pdf


Diane Link
Diane Link

Diane Link has over 25 years of home health and hospice experience. She is currently owner of Link Healthcare Advantage, providing home health and hospice consulting services including operation assessments, survey readiness, regulatory and compliance programs, outsource QAPI program and outcome improvements. Diane is also COO and partner with Curaport, an online education platform for post-acute care providers. Her experience includes a variety of roles in home health and hospice from field nurse to executive director, and was a surveyor for home health, hospice, and private duty services for CHAP (Community Health Accreditation Partners) for the past five years as both an independent consultant and as a director of clinical consulting at a large consulting company.

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