October 31, 2018
While January 2019 will not bring the same level of chaos and change to the home health industry that January 2018 did, there are several changes coming.
One of the big changes that is happening is the update of the OASIS from OASIS C2 to OASIS D.
There are many positive things about the changes that will be happening to OASIS – several questions are being removed altogether, which may even help to decrease the amount time and work that’s required to complete the questions.
However – if you haven’t started to educate your staff on this update – you should! There are several new questions being added to the OASIS in the new D version, and they are no treat!
These questions are being referred to as “composite” measures (you may be familiar with the term from outcomes reporting) and they comprise several characteristics of the current M1800 questions (which are still in for now).
The thing that’s spooky about these composite measures is the specificity that they require, particularly regarding questions that could in turn be used against your agency as they relate to homebound status – significant detail down to the minutia of whether the patient is able to turn themselves to the right or the left in the bed.
These questions will take some getting used to, and could be a land mine for agencies that employ nurses completing them who do not understand the rationale or the conventions of completing OASIS.
If you have not yet educated your staff regarding the upcoming changes – you should! Don’t get left behind on this important rule.
The OASIS D guidance Manual is linked here: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/draft-OASIS-D-Guidance-Manual-7-2-2018.pdf
Need help? Call us at 940-427-2488!
October 24, 2018
October 17, 2018
Review Choice demonstration, which was scheduled to begin in Illinois on October 1, 2018 has been pushed to implementation “no earlier than” December 10, 2018 (unless it’s halted further!) and Medicare has re-opened the comment period.
This is your chance to make your voice heard! Post comments online and let CMS know what you think as a stakeholder in the process here: https://www.federalregister.gov/documents/2018/09/27/2018-20994/agency-information-collection-activities-submission-for-omb-review-comment-request
Hurry though – the comment period ends on the 29th, and this time, it will likely not be extended.
Review Choice Demonstration – is essentially Pre-claim review 2.0
It contains many of the same requirements as the original Pre-claim review from 2015/16, including the requirement that agencies must submit required documents like the F2F/H&P, etc. prior to submitting EOE billing, or risk losing 25% of their reimbursement. Updates to the proposed implementation are happening all the time, the following are taken from CMS’ FAQ’s regarding the demonstration, and at this point are still correct.
10. How long will the demonstration last?
The revised demonstration is for five years. Additional information will be released in the coming months.
4. What states does this demonstration impact?
CMS will stagger implementation of the Demonstration, beginning with the state of Illinois, then expanding to Ohio and North Carolina, and later to Texas and Florida. CMS has the option to expand to other states in the Palmetto/JM Home Health and Hospice Medicare Administrative Contractor jurisdiction if there is increased evidence of fraud, waste or abuse in these states during the demonstration period.
October 8, 2018
Please see the link for some GREAT information on Medicare Advantage for Private Duty Agencies.
October 3, 2018
This week, we wanted to remind agencies that patients should have received or be
receiving their updated Medicare Identification card.
The updated Medicare ID card is no longer called a “Medicare card”, it is now called a Medicare Beneficiary Identifier.
Updated cards showing this number (and not the previous SSN-based number)
started to be mailed out in April of this year.
The Texas roll-out began June 1, 2018, but is still ongoing, the process has started/
stopped in Texas over the course of the roll-out, so not all patients have received their updated card yet, but by regulation, the roll out must be completed to all patients by April 1st of 2019.
It’s important for clinicians to remember that any time CMS makes a sweeping
change such as this, unscrupulous people will come out of the wood work
to try and take advantage of elderly patients. Make sure that your clinicians
know about the updated card, and are checking with patients on an ongoing
basis to see if it’s been received, as well as to warn them about the potential for fraud. Find more information about the MBI here:
September 26, 2018
FOR: Those who administer medications – Nurses, unlicensed personnel through delegation, and the client’s caregivers
We’re familiar with the five rights of medication administration: the right client, the right medication, the right dose, the right route, and the right time. Did you know that this list has grown over the years to eight? The additional three rights of medication administration are: the client’s right to know information about the drug, the client’s right to refuse the drug, and the responsibility of the person who administers the medication to complete the right documentation.
Whether there are five or eight, our clients are entitled to receive safe and appropriate care.
September 21, 2018
All providers transitioning to DataLogic Vesta EVV from MEDsys VinCENT must complete their transition by Sept. 30, 2018. If you do not have a transition date, please contact DataLogic immediately at firstname.lastname@example.org. Requests to delay a transition past Sept. 30, 2018, will not be accepted.
The last day to access the MEDsys VinCENT system for any reason (review data, generate reports, do visit maintenance, etc.) is Oct. 28, 2018.
For questions regarding this alert, please contact Electronic_Visit_Verification@hhsc.state.tx.us.
September 19, 2018
While the state’s top 10 deficiencies list will not address the updated Conditions of Participation (COP’s) for some time, our friends at ACHC (Accreditation Commission for Healthcare) have published a list of their anticipated top 10 deficiencies. Find that list, along with some compliance tips here:
When looking at maintaining compliance with the updated Conditions of Participation (can you believe it’s almost been a year?!) remember that requirements for the plan of care were one of the most updated items.
Are you remembering to include:
- Patient’s progress to goals?
- Detailed certification statement?
- DNR/Advance Directive status? (with detail)
- Psychosocial status?
We see many agencies missing these key elements when reviewing plans of care. Please make sure that yours measure up!
September 12, 2018
This week, something has changed at CMS via the QIES login system that you might not be aware of!
Agencies who’s login began with the letter “H” have had that user name deleted from CMS’ systems, and it is no longer valid.
There is no grace period, and if you try to login using this user ID, it is completely invalidated. The solution? Go online and apply for a new login at:
You’ll find this:
Please note, there is an “FAQ” tab here,
But there are no FAQ’s actually populated
If you need further assistance with the process
You’ll have to call the CMS number provided on the site.
September 10, 2018
FOR: All licensure categories
HHSC has developed a Provider Investigations Handbook, effective September 1, 2018. The Handbook describes HHSC’s investigations of Abuse, Neglect, and Exploitation of individuals receiving care from providers. The Handbook can be found at: https://hhs.texas.gov/laws-regulations/handbooks/provider-investigations-handbook
September 6, 2018
Have you gotten TULIP yet? Well we’d like to give you some. Allergic to flowers? Not serious yet? No problem! We’re talking about this Tulip:
T – Texas
The state of Texas has recently unveiled its new program, which will be the way that agencies in Texas can:
- Apply for new licenses and renewals.
- Receive updates and check application statuses online
- Changes to current agencies (such as those found on the 2021) Administrator, etc.
- Link to Self-Reporting
One nice thing about the electronic version of forms such as the 2021, is that only the required parts of the form will populate when the user tells the system what type of change it is making, leading to less confusion, and more accepted changes!
Like other state websites, the state requires that only authorized users are able to have a “security authority” at the agency that will have the ability to set up the system for the agency.
Note: The rollout date for the system is 9/4/18. “Key” letters will be sent to each licensed agency in the state, so be on the lookout for these letters – you will need to have that key in order to register your agency.
THHS has published its recorded webinar here:
The “main” TULIP web site (which will include FAQ’s):
September 4, 2018
TIMELY TIP FOR AGENCIES WITH PAS CATEGORY OF LICENSE
For those of you who provide Personal Care Services (PCS) through the Texas Medicaid and Healthcare Partnership (TMHP), we want to be sure you know that Electronic Visit Verification (EVV) has been delayed until January 1, 2020. The 21st Century Cures Act originally required home health agencies to begin adopting EVV systems on January 1, 2019. The bill to delay EVV was widely supported by the legislature.
August 31, 2018
TIMELY TIP FOR AGENCIES WITH LCHHS, LHHS, AND PAS CATEGORIES OF LICENSE
Last week, we read an announcement from an accrediting body reminding agencies of THEIR requirements for independent contractors. We think it’s a good time to remind licensed agencies of the Home and Community Support Services Agencies (HCSSA) Standard related to Independent Contractors in Rule 97.289. The Agency must have a contract with each independent contractor that clearly designates:
· that clients are accepted for care only by the agency;
· the services to be provided by the contractor and how they will be provided (i.e. per visit, per hours, etc.);
· the necessity of the contractor to conform to all applicable agency policies, including personnel qualifications;
· the contractor’s responsibility for participating in developing the plan of care, care plan, or individualized service plan;
· the manner in which services will be coordinated and evaluated by the agency…and
· the procedures for:
§ submitting information and documentation by the contractor in accordance with the agency’s client record policies;
§ scheduling of visits by the contractor or the agency;
§ periodic client evaluation by the contractor; and
§ determining charges and reimbursement payable by the agency for the contractor’s services under the contract.