ACHC Updates COVID-19 FAQs for Providers

 In Advocacy, Covid-19

Allume is Medicare-accredited through Accreditation Commission for Healthcare (ACHC).  Given that ACHC is our accrediting body, we pay close attention to their guidelines on how to navigate during the pandemic.

ACHC recently released COVID-19 FAQs for Providers which includes an abundance of important information for home health providers.

Below is a subset of key areas to bring to our attention.  Bear in mind that these are for federal regulations overseen by ACHC and do not necessarily account for additional rules and regulations required by state and local authorities.  This solely answers questions from the perspective of our federal requirements as seen by ACHC.

Q: Can my home health agency conduct telehealth visits instead of home visits?
A: Under CMS waivers during the COVID-19 public health emergency, home health agencies (HHAs) can use telehealth to provide more services to beneficiaries within the 30-day episode of care, if the services are part of the patient’s plan of care and do not replace
needed in-person visits, as ordered on the plan of care. The use of such technology may result in changes to the frequency or types of in-person visits outlined in existing or new plans of care.

Q: Is it true that initial home health assessments can be conducted remotely?
A: With the CMS waiver of 42 CFR § 484.55(a), HHAs can perform initial assessments and determine patients’ homebound status remotely or by record review. This will allow patients to be cared for in the best environment for them while supporting infection control and reducing impact on acute-care and long-term care facilities. This will allow for maximizing coverage if there are limited physician and advanced
practice clinicians and will allow those clinicians to focus on caring for patients with the greatest acuity. The plan of care should be modified to reflect which visits will be made in person and which visits will be conducted via telehealth.

Q: What if the patient refuses all home visits?
A: While there are some aspects of care that can be done via telehealth, not everything can be accomplished by telehealth when skilled care is required. The HHA will have to work closely with the patient to determine what would help to reassure them that visits from home care staff are safe. If the patient continues to refuse any in-person visits as per the plan of care, including assessment or other patient care visits, the
HHA will have to determine if the HHA can meet the patient’s medical, nursing, rehabilitative, and social needs in his or her place of residence (§484.60).

Q: Has the homebound definition for home health patients been affected during the national emergency?
A: Yes. CMS has altered the definition during the emergency. Homebound definition: A beneficiary is considered homebound when their physician advises them not to leave the home because of a confirmed or suspected COVID-19 diagnosis or if the patient has a condition that makes them more susceptible to contract COVID-19. As a result, if a beneficiary is homebound due to COVID-19 and needs skilled services, an HHA can provide those services under the Medicare home health benefit.

Q: Do I need to supervise a home health aide on site every 14 days?
A: CMS has waived the requirements at 484.80(h), which require a nurse to conduct an on-site visit every two weeks. This includes waiving requirements for a nurse or other professional to conduct an on-site visit every two weeks to evaluate if aides are providing care consistent with the care plan, as that may not be physically possible for a period of time. This waiver also temporarily suspended the two-week aide
supervision requirement at 42 CFR §484.80(h)(1) by a Registered Nurse for home health agencies, but virtual supervision is encouraged during the period of the waiver.

Q: For purposes of the statutory requirement that a patient have a face-to-face encounter with a physician or an allowed non-physician practitioner in order to qualify for Medicare home health care, can this encounter occur via telehealth during the pandemic?
A: The face-to-face encounter, as described at 1814(a) (2)(C) and 1835(a)(2)(A) of the Social Security Act, can be performed via telehealth, in accordance with the requirements under 1834(m)(4)(C) of the Social Security Act. Under the expansion of telehealth under the CMS 1135 waiver, beneficiaries are able to use telehealth technologies with their doctors and practitioners from home (or other originating site) for
the face-to-face encounter to qualify for Medicare home health care.

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You can access the full COVID-19 FAQs for Providers here. 

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