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CMS Hospice Relief

May 7, 2020 1:38:14 PM / by Dante Hernandez

As COVID-19 numbers increase - CMS has released new guidelines

As portions of the United States start to resume “normal” operations, the Center for Medicare and Medicaid Services (CMS) has released another round of waivers targeted towards the Hospice industry. With fresh guidance on timelines - CMS is actively working to provide resources to relieve some stress for healthcare workers nationwide. In line with previous guidelines, these changes go into effect immediately without healthcare providers having to request waivers from CMS.

Remote Tools

This round of waivers focused on providing telehealth solutions to Hospice patients where feasible. Previously, CMS only briefly mentioned how Hospice fits into the remote care stating, “CMS is allowing telehealth to fulfill many face-to-face visit requirements...” In the latest version, it outlines the usage of phone calls, either audio-only or TTY (teletypewriter), and 2-way-synchronous audio-video calls.

Live video chat is an essential part of fulfilling hands-on interactions as a way to establish a presence or include a variety of specialists to see and work with patients. Federal agencies are assisting providers nationwide as the Federal Communications Commission has earmarked $200 million for the expansion of telehealth services. With the Public Health Emergency (PHE) continuing into the foreseeable future, we will most likely not see a decline in the usage of video chat as an essential resource for telehealth.

Timeline Updates

Deadlines for a variety of requirements have been extended to ease the paperwork demanded by CMS. Reviewing the full guidelines will provide the greatest insight for your practice.

Requirements around having home health aides directly observed by a Home Health Aide (HHA), by an e.g., registered nurse, or physical therapist have been postponed. It is one of the two items that are postponed until the conclusion of the PHE. Annual direct observation of staff will resume 60 days after the end of the ongoing PHE.

Annual assessments of those who provide care have been postponed “until the end of the first full quarter after the declaration of the PHE concludes”. This is not changing the minimum requirements for personal working at a Hospice provider

Volunteer requirements have changed due to the concern for reliable participants during the COVID-19 pandemic. Removing the need for volunteers to provide 5% of total patient care hours of paid Hospice employees.

Certain requirements of QAPI has been narrowed down to focus on “infectious control issues” and the tracking of adverse events for the duration of the PHE.

As stated in the waivers released last month, home visitations every two weeks are not required if it does not affect a patient’s care plan.

Patients Over Paperwork

  • There is now an extension allowing for a comprehensive assessment of patients to be extended from 15 to 21 days.
  • Non-care services have been waived, such as physical therapy, occupational therapy, and speech-language pathology.

CMS has expedited the “Accelerated and Advance Payments Program” to provide funds for payments to providers and suppliers - which CMS has paid over $100 billion to healthcare providers and suppliers. Along with currently re-evaluating all pending and new applications for the Accelerated Payment Program and a suspension of the Advance Payment Program due to payments through the Department of Health & Human Services’ (HHS) Provider Relief Fund, payments from the Provider Relief Fund do not need to be repaid. Those who have received accelerated or advance payments related to the PHE, CMS will delay repayments until 120 days after the date of receiving their payments.

Long Term Care

CMS has separately released waivers for Long Term Care facilities to go into effect immediately. With a wide-ranging scope for these waivers, here are a few key highlights:

  • Reporting cases of COVID-19 among staff to the CDC
  • Alerting families of suspected cases of COVID-19
  • Mitigation of the spread of COVID-19 (allowing transfers when possible)
  • Waiving requirements for in-person, resident group meetings
  • Postponing deadlines for e.g., paperwork and training
  • Waivers will not interrupt standard maintenance/testing for safety tools (fire extinguishers, generators) inside of in-patient facilities

CMS continues to provide more guidelines as this PHE evolves over time, and staying up to date is essential. For more information on CMS waivers, click here.

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Tags: virtual visits, telehealth

Dante Hernandez

Written by Dante Hernandez