January 2022 CMS Quarterly OASIS Q&As

The recently released January 2022 Quarterly OASIS Q&As reiterated the CY 2022 Home Health Final Rule confirming that OASIS-E will begin on January 1, 2023, instead of the originally estimated time frame of one full year after the end of the COVID-19 Public Health Emergency. They went on to say that CMS will release a…

OASIS-E & High-Risk Medications

Medicare-certified home health agencies will be required to implement the use of OASIS-E on January 1, 2023.  An announcement by CMS last month stating the Office of Management and Budget (OMB) had approved the extension of OASIS-D until November 2024 was confusing to many of us.  It seemed to directly contradict the Home Health Final…

COVID-19 Regulatory Changes

Recently, changes have occurred in the COVID-19 government mandates.  Only two vaccine mandates are currently in effect, but the changes have caused much confusion. Adding to that, half of the nation’s states have current litigation pending and will not have surveyor enforcement of the CMS vaccine mandate. It’s enough to make your head spin!  Things…

COVID-19 Regulatory Guidance

As of 12/29/2021: CDC Guidance for Isolation and Quarantine Protocols If you have a positive COVID-19 test (regardless of vaccination status): Stay isolated for 5 days If no symptoms exist, or symptoms lessen after 5 days, you may leave your house but only with a mask for 5 additional days If symptoms persist, including fever,…

Occupational Therapist CoP Changes

Year 2022 is almost here and those of us in home health care must consider the Final Rule and changes which become effective on January 1, 2022.  One alteration to the Conditions of Participation is the allowance of an occupational therapist to perform the initial visit and comprehensive assessment.  This is a bit of a…

Notice of Admission

The Notice of Admission (NOA) is on the horizon for Medicare-certified home health agencies.  Beginning January 1, 2022, the NOA will replace the no-pay RAP.  This notification to Medicare will be a one-time requirement from admission to discharge (replacing the every 30 day no-pay RAP).  The same penalties apply for non-timely filing past the required…

COVID-19 Vaccination & Testing Mandates Suspended

On December 2, 2021, CMS released a memorandum from the Quality, Safety & Oversight Group (QSOG) and Survey & Operations Group (SOG) stating that CMS has “suspended activities related to the implementation and enforcement of the Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff  Vaccination pending future developments in the litigation. Accordingly, while these…

COVID-19 Vaccination & Testing Mandates

Two new COVID-19 vaccination mandates were released two weeks ago.  This is addition to the previously established OSHA Healthcare ETS and many state and local rules regarding COVID-19.  The information overload is real as you determine which rule or more than one rule applies to your organization.  But, here’s the short story on the two…

Home Health Value Based Purchasing

As you have probably heard, the Home Health Value Based Purchasing (HHVBP) model has been finalized in the Home Health Final Rule for next year and includes all home health Medicare-certified agencies across the United States, territories, and District of Columbia.  However, a change in the full enactment of the program was a happy announcement…

Home Health & Hospice Regulatory Updates

The first week of November has been newsworthy for the home health and hospice care sectors.  The Home Health Final Rule, CMS-1747-F, was released on Tuesday afternoon.   If that wasn’t enough to digest, both OSHA and CMS released rules on COVID-19 vaccination.  There’s a lot of information to be processed in the coming days.  However…