Vaccination Expectations for Surveyors

The Centers for Medicare & Medicaid Services (CMS) recently updated its vaccination expectations for surveyors.  In January of this year CMS issued a memo (QSO-22-10-ALL) requiring state agency surveyors and accrediting organization (AO) surveyors performing deemed status surveys to not participate in onsite surveys unless fully vaccinated (unless vaccination is medically contraindicated or the individual…

Free Webinar on Forthcoming CMS Pilot to Test Transmission of Hospice Election Data to Part D Plans

The National Association for Home Care & Hospice (NAHC) and other stakeholder groups have been working with the National Council of Prescription Drug Plans (NCPDP) to improve coordination between hospice providers and Part D plans to ensure appropriate coverage for prescription drugs while patients are on hospice service.

A key issue believed to play a significant role in poor coordination is the length of time it takes for information about a patient’s hospice election to filter through the Centers for Medicare & Medicaid Services’ (CMS’) systems to the Part D prescription drug plans.

CMS is now set to launch a pilot study under which hospice EMR vendors, clearinghouses, and Part D plans will test whether hospice election information can be transmitted more timely from hospice EMR vendors/clearinghouses via an intermediary (called the Part D Transaction Facilitator) directly to the patient’s Part D plan.

In an effort to educate hospice providers, Part D plans, hospice EMR vendors/clearinghouses, and other interested parties, NCPDP is hosting a FREE WEBINAR on June 29 to describe the how the pilot will work. The pilot will utilize the Notice of Election (NOE) 837I Transaction Standard to provide information for the Part D Transaction Facilitator, who will create the NCPDP Telecommunication Standard Nx real-time Hospice enrollment transactions for submission to the Medicare Part D plans. The intent of this new process is to allow for timely Hospice election notification to Medicare Part D Plans.

ABOUT THE WEBINAR

Background:  Join this webinar to learn about a pilot initiative to solve for Hospice enrollment notification delays sent to the Medicare Part D plans that may result in inappropriate payments made by the Medicare Part D plans during a Hospice election period

Date/Time:  June 29, 2022, 1 p.m. EASTERN

Learning Objectives: 
After this educational session, attendees will be able to:

  • Understand the journey from delayed information to real-time information.
  • Describe the Hospice Election Status Nx Transactions and all they do.
  • Learn about becoming an NCPDP/CMS Hospice Election Status pilot participant.

Registration:  To register, go to the following link:  NCPDP – Webinars. Scroll down to Upcoming Webinars and click on Hospice Election Status NCPDP/CMS Pilot. Please note that while most NCPDP webinars require payment, this webinar is complimentary.

Vaccination Expectations for Surveyors

The Centers for Medicare & Medicaid Services (CMS) recently updated its vaccination expectations for surveyors.  In January of this year CMS issued a memo (QSO-22-10-ALL) requiring state agency surveyors and accrediting organization (AO) surveyors performing deemed status surveys to not participate in onsite surveys unless fully vaccinated (unless vaccination is medically contraindicated or the individual is legally entitled to a reasonable accommodation under federal civil rights laws because they have a disability or sincerely held religious beliefs, practices, or observances that conflict with the vaccination requirement).

That memo whas been rescinded.

With QSO-22-18-ALL CMS encourages surveyors conducting federal surveys to be vaccinated but does not require it (or an acceptable exemption).  It remains up to the survey entity to implement policies around COVID-19 vaccination (and exemptions).

Previous guidance for surveyors entering nursing homes was provided in QSO-20-39-NH and this guidance remains.  While it is not directly applicable to home health and hospice providers, it may be applicable to some hospice inpatient facilities. Additionally, some state survey agencies and AOs have incorporated this guidance into their policies and procedures. It is expect that home health and hospice providers will not request vaccination status of surveyors or restrict surveyor access based on vaccination status.

Surveys for Compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements

This is an update to a NAHC Report article published on June 15, 2022.

Previously, NAHC reported that the Centers for Medicare & Medicaid Services (CMS) posted memo QSO-22-17-ALL containing new instructions for surveys for compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements. CMS previously issued guidance and survey procedures to survey entities for assessing and maintaining compliance with the regulatory requirements for vaccination.

Under the previous guidance, federal, state and Accreditation Organization (AO) surveyors were to assess for compliance with the vaccination requirements at surveys for initial certification, standard recertification or reaccreditation, and complaint surveys.

Effective immediately, surveyors will continue to survey for compliance with the vaccination requirements during initial and recertification surveys, but will now only survey for compliance in response to complaints alleging non-compliance with this requirement (not all complaint surveys). NAHC received clarification from CMS that any complaint survey addressing infection control and not just the COVID-19 vaccination requirements specifically, will include a review of the provider’s compliance with the vaccination requirements.  Since these requirements became effective earlier this year, 95% of the nearly 12,000 providers that have been surveyed by states are in compliance with the requirements.

This most recent memo also instructs state survey agencies to reach out to their CMS Location if they are considering citing vaccine requirements at immediate jeopardy, Condition or actual harm levels. CMS is reviewing its previous interpretive guidance describing Immediate Jeopardy, Condition-level and actual harm determinations to ensure that deficiency citations recognize good faith efforts by providers/suppliers and to more fully evaluate harm or potential harm to patients/residents by considering trends in COVID-19 rates in the community.  Stay tuned to NAHC Report for more information on these updates as they become available.

Update to ‘J’ Drug Code List for Billing Home Infusion Therapy Services

(Before we get to the story, please note that NAHC will hold a critically important webinar, What the CY2023 Home Health Proposed Payment Rule Means for Your Agency. “The stability of home health care is at risk,” said NAHC President William A. Dombi, in reaction to the release of the CY2023 home health proposed payment update rule. “What…

CMS Revises Instructions to Claim Edit for Hospice Transfers

As previously reported, in July 2022 a claims processing edit to prevent gap billing between hospice transfers will be implemented. A gap is most likely to occur in situations where a patient requests to transfer to a hospice that is outside of the geographic service area and requires some time of travel. The Centers for Medicare…

Free Webinar on Forthcoming CMS Pilot to Test Transmission of Hospice Election Data to Part D Plans

The National Association for Home Care & Hospice (NAHC) and other stakeholder groups have been working with the National Council of Prescription Drug Plans (NCPDP) to improve coordination between hospice providers and Part D plans to ensure appropriate coverage for prescription drugs while patients are on hospice service. A key issue believed to play a…

CMS Proposed Rule Risks Stability of Home Health Care

NAHC analysis of payment information & more The Centers for Medicare and Medicaid Services (CMS) issued its annual proposed rule regarding Medicare home health services payment rates for CY 2023. As usual, the rule also includes a hodgepodge of non-rate related proposals as well. This article provides a summary of the proposed rule. NAHC will…

Free Webinar on Future CMS Pilot to Test Transmission of Hospice Election Data to Part D Plans

The National Association for Home Care & Hospice (NAHC) and other stakeholder groups have been working with the National Council of Prescription Drug Plans (NCPDP) to improve coordination between hospice providers and Part D plans to ensure appropriate coverage for prescription drugs while patients are on hospice service.

A key issue believed to play a significant role in poor coordination is the length of time it takes for information about a patient’s hospice election to filter through the Centers for Medicare & Medicaid Services’ (CMS’) systems to the Part D prescription drug plans.

CMS is now set to launch a pilot study under which hospice EMR vendors, clearinghouses, and Part D plans will test whether hospice election information can be transmitted more timely from hospice EMR vendors/clearinghouses via an intermediary (called the Part D Transaction Facilitator) directly to the patient’s Part D plan.

In an effort to educate hospice providers, Part D plans, hospice EMR vendors/clearinghouses, and other interested parties, NCPDP is hosting a FREE WEBINAR on June 29 to describe the how the pilot will work.   The pilot will utilize the Notice of Election (NOE) 837I Transaction Standard to provide information for the Part D Transaction Facilitator, who will create the NCPDP Telecommunication Standard Nx real-time Hospice enrollment transactions for submission to the Medicare Part D plans. The intent of this new process is to allow for timely Hospice election notification to Medicare Part D Plans.

ABOUT THE WEBINAR

Background:  Join this webinar to learn about a pilot initiative to solve for Hospice enrollment notification delays sent to the Medicare Part D plans that may result in inappropriate payments made by the Medicare Part D plans during a Hospice election period

Date/Time:  June 20, 2022, 1 p.m. EASTERN

Learning Objectives: 
After this educational session, attendees will be able to:

  • Understand the journey from delayed information to real-time information.
  • Describe the Hospice Election Status Nx Transactions and all they do.
  • Learn about becoming an NCPDP/CMS Hospice Election Status pilot participant.

Registration:  To register, go to the following link:  NCPDP – Webinars. Scroll down to Upcoming Webinars and click on Hospice Election Status NCPDP/CMS Pilot. Please note that while most NCPDP webinars require payment, this webinar is complimentary.

Surveys for Compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements

The Centers for Medicare & Medicaid Services (CMS) posted memo QSO-22-17-ALL containing new instructions for surveys for compliance with Omnibus COVID-19 Health Care Staff Vaccination Requirements. CMS previously issued guidance and survey procedures to survey entities for assessing and maintaining compliance with the regulatory requirements for vaccination.

Under the previous guidance, federal, state and Accreditation Organization (AO) surveyors were to assess for compliance with the vaccination requirements at surveys for initial certification, standard recertification or reaccreditation, and complaint surveys.

Effective immediately, surveyors will continue to survey for compliance with the vaccination requirements during initial and recertification surveys, but will now only survey for compliance in response to complaints alleging non-compliance with this requirement (not all complaint surveys).  Since the vaccination requirements became effective earlier this year, 95% of the nearly 12,000 providers that have been surveyed by states are in compliance with the requirements.

This most recent memo also instructs state survey agencies to reach out to their CMS Location if they are considering citing vaccine requirements at immediate jeopardy, Condition or actual harm levels.  CMS is reviewing its previous interpretive guidance describing Immediate Jeopardy, Condition-level and actual harm determinations to ensure that deficiency citations recognize good faith efforts by providers/suppliers and to more fully evaluate harm or potential harm to patients/residents by considering trends in COVID-19 rates in the community.

Stay tuned to NAHC Report for more information on these updates as they become available.