The Centers for Medicare and Medicaid Services (CMS) recently published policy updates related to Medicare telehealth services. In 2019 CHS finalized the definition of remote patient monitory as the “collection of physiologic data (electrocardiogram, blood pressure, glucose monitoring) digitally stored or transmitted by the patient or caregiver to the HHA. With the onset of the…
CMS Quarterly Q&As
CMS released the January 2023 Quarterly Q&As on Tuesday and among many topics, there is continued confusion surrounding the transition period. The Q&A guidance reiterates that the M0090 Date determines which version of the OASIS to complete and not necessarily the beginning date of the episode of care. The quarterly Q&As address questions that arise from real-life…
Personnel Files Compliance
The dawn of a new year is the perfect time to ensure your organization is on-track with regulatory issues. An often overlooked area is personnel files. It’s easy to assume everything is complete once an employee has finished their orientation process. However, there are annual education requirements to maintain. The first quarter of each year…
OASIS-E: M0090
The transition to OASIS-E is upon all Medicare certified home health agencies. In the January 2022 CMS OASIS Q&As (category 2, Q/A 1), clarification was the OASIS item, M0090, establishes whether OASIS-D1 or OASIS-E will be the required data set. As a reminder, the M0090 item is the last date information is used to complete…
Homebound Status
The inability to leave home—homebound status–for patients receiving home health care services has plagued agencies since its inception. It has been the source of many heated discussions in team meetings, has it not? Initial assessments of patients typically start out strong with reasons the patient is unable to leave his or her home without a…
Hospice Plan of Care Deficiency
Plan of Care, L-Tag 543, is one of the top cited deficiencies in hospice. This means the hospice failed to ensure all hospice care and services provided to patients and families followed an individualized written plan of care established by the interdisciplinary group. Collaboration with the attending physician (as applicable), patient or patient representative, and…
Home Health Referral
The beginning of every home health services admission or resumption of care starts with a referral. It seems so simple. However, just what is required for a referral to be valid? Home health agencies continue to struggle with this and are negatively affected by the process measure, timely initiation of care, when an invalid referral…
Hospice Governing Body
Hospices are required to have an organized governing body that has complete and ultimate responsibility for the organization, including legal and financial authority. This condition of participation—§418.100 and §418.58–requires the governing body to be informed of the hospice’s ongoing operations, including patient care delivery issues and QAPI activities. It’s imperative there is evidence of the…
Home Health Quality Reporting
In case you missed it, the 2023 Home Health Prospective Payment System Rate Update, Home Health Quality Reporting Program Requirements: Home Health Value-Based Purchasing Expanded Model Requirements; and Home Infusion Therapy Services Requirements Final Rule was released on October 31, 2022. The published version is scheduled for release on 11/04/2022. For the preview version, click on the…
Prediction of Terminal Illness
Prediction of terminal illness can be difficult for hospices. Local Coverage Determinations (LCDs) are guidelines developed by Medicare Administrative Contractors (MACs)—CGS, NGS, and Palmetto GBA—to assist hospices determine hospice eligibility. Although LCDs are not regulatory, the MACs use the LCD criteria in medical review. Therefore, hospice organizations are wise to follow the LCDs as much…
