The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE

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2 Today s educational presentation is provided by The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE sales@kinnser.com

3 About the presenter SHARON HARDER President C3 Advisors, LLC More info: c3advisors.com

4 About the presenter JILL DYER BSN, RN, HCS-D, HCS-O Home Health Executive, Consultant J.I.D. Consulting

5 Basic Facts!Effec3ve date is now January 13, 2018!Excep3on is the Emergency Preparedness Rule which takes effect November 15, 2017!Interpre3ve Guidelines and changes to the SOM, Appendix B are s3ll pending! Compliance with the new condi3ons will be mandatory

6 On the Surface! Significant changes to the sec3ons and numbering of the Code of Federal Regula3ons related to HH services! There are two new Condi3ons of Par3cipa3on! Quality Assessment and Performance Improvement QAPI! Infec3on Preven3on and Control! Three requirements have been eliminated! Subunits will no longer be recognized! Professional Advisory CommiYee is eliminated along with quarterly record reviews! 60-Day Summary will no longer be required

7 Gaining Direc7on The Guiding Principles of the New CoPs! Development of a con3nuous integrated care process across all aspects of service based on pa3ent-centered assessments, care plans, service delivery, quality assessment and performance improvement! Interdisciplinary approach to meet pa3ent needs with outcome and data-driven quality improvements! Elimina3on of administra3ve process requirements that do not contribute to quality pa3ent outcomes! Implementa3on of processes to safeguard pa3ent rights

8 The Top 10 Changes 1. Expansion of Pa3ent Rights 2. Implementa3on of QAPI 3. Infec3on Preven3on and Control 4. Comprehensive Assessments 5. Plans of Care 6. Verbal Orders 7. Clinical Records 8. Governing Board Authority 9. Administrator Qualifica3ons 10. Emergency Preparedness

9 The New Rules Subpart A: Basis and Scope Defini3ons Subpart B: Release of Iden3fiable OASIS Pa3ent Informa3on Repor3ng OASIS Pa3ent Rights Comprehensive Assessment of Pa3ents Care Planning, Coordina3on of Services and Quality

10 The New Rules con3nued Subpart B: Quality Assessment and Performance Improvement (QAPI) Infec3on Preven3on and Control Skilled Services Home Health Aide Services Subpart C: Compliance with Federal and State Laws Emergency Preparedness Organiza3on and Administra3on of Services Clinical Records Personnel Qualifica3ons

11 Today s Agenda Two-pronged focus What you should know and what you should do now to prepare! Basis, Scope and Key Defini3ons! Compliance Requirements State and Federal Laws! Emergency Preparedness! Organiza3on and Administra3on of Services! Clinical Records! Personnel Qualifica3ons

12 SUBPART A ORGANIZATIONAL ENVIRONMENT

13 Basis and Scope How did we get here?! It all started in CMS proposed an en3re set of revisions including the addi3on of OASIS! But only the OASIS rules were adopted! Effect of MMA in 2003 imposi3on of the 3-year rule for new regulatory proposed rules! New set of proposed CoPs published in 2014 and finalized in 2017! Originally slated for implementa3on in July 2017 and postponed un3l January 2018

14 Defini3ons! Parent agencies, branches and subdivisions! In advance! Quality indicator! Representa3ve! Clinical Note! Verbal Order! Summary Report

15 Defini3ons Branches versus Subunits! Parent must now provide supervision and administra3ve control! Geographic proximity described as sufficiently close is no longer included! Viola3ons of a CoP in a branch office apply to the en3re agency! On the effec3ve date, any subunits will be considered dis3nct home health agencies that will be required to independently meet all CoPs! Current subunits can apply to become branches if certain criteria are met

16 SUBPART C ORGANIZATIONAL ENVIRONMENT

17 Compliance with Laws and Regula3ons! Compliance with Federal, State and local laws and regula3ons related to the health and safety of pa3ents.! (a) Disclosure of ownership and management informa3on not new! (b) Licensing standards The agency, its branches and all persons furnishing services must be licensed, cer3fied or registered, as applicable in accordance with State licensing authority and must meet those requirements not new

18 Regulatory Compliance - Lab Tes3ng (c) Laboratory Services new! If the agency performs tes3ng other than assis3ng pa3ents with self-administered tes3ng, the agency must use the pa3ent s equipment

19 Regulatory Analysis Lab tes3ng excep3ons! Agency equipment may be used for short, defined periods when pa3ent equipment is not yet available! Generally, a period of days when equipment is pending for delivery following the physician s order! Agencies should assist pa3ents in obtaining tes3ng equipment! If the pa3ent refuses to obtain equipment, the agency may discharge the pa3ent aler thoroughly documen3ng the circumstances and its ac3ons

20 Emergency Preparedness Emergency Preparedness! Effec3ve November 15, 2017! Agencies must develop a plan that is reviewed at least annually! Four core planning elements! Risk assessment! Emergency and disaster policies and procedures! Communica3on planning! Tes3ng and training

21 Emergency Preparedness Risk Assessment! All hazards approach to risk assessment! Any credible risk must be evaluated and the subject of planning! Natural and man-made risks should be addressed

22 The Emergency Plan! Based on assessed, probable risk! Updated annually! Strategies for addressing emergency events! Plans for business con3nuity and pa3ent/staff safety! Preserva3on of assets and records! Coopera3on with local emergency coali3ons and agencies

23 Emergency Policies and Procedures! To be developed based on specific assessed risks! Individual pa3ent risk planning as a part of each assessment in accordance with ! Procedures for no3fying authori3es about pa3ent evacua3on needs! Procedures for staff follow-up! Procedures for preserving and accessing medical records that protects pa3ent confiden3ality! Use of volunteers during an emergency

24 Emergency Communica3on Plan! Must have names/contact informa3on to! Staff members! Contracted service providers! Pa3ent physicians! Federal, State, tribal, regional or local emergency preparedness staff! Other sources of assistance! Primary and alternate means of communica3ons! Method for sharing medical documenta3on and pa3ent loca3on! Methods for providing informa3on about ability to con3nue opera3ons

25 Emergency Training! All staff must be trained at least annually! New hires should be training, ini3ally, as a part of their orienta3on! Staff knowledge of emergency policies and procedures is required! Training must be documented

26 Emergency Tes3ng! Agencies must test the plan and response procedures at least annually! Tes3ng involve a full-scale exercise that ideally will be a communitybased, mul3-facility tes3ng exercise! If an agency experiences an actual emergency or disaster, it will be exempted from a full-scale exercise for one year! An addi3onal exercise can include a table-top simulated exercise! Responses must be analyzed for the purpose of upda3ng the plan as necessary

27 Organiza3on Organiza3on and Administra3on of Services The HHA must organize, manage and administer its resources to ayain and maintain the highest prac3cable func3onal capacity, including providing op3mal care to achieve the goals and outcomes iden3fied in the pa3ent s plan of care, for each pa3ent s medical, nursing and rehabilita3ve needs.

28 Administra3ve and Supervisory Func3ons! Cannot be delegated! All services not directly furnished are monitored and controlled! The agency must frame the organiza3onal structure in wri3ng including services offered and lines of authority! None of these requirements are new

29 The Governing Body! Must have full legal authority and responsibility for agency s overall management and opera3ons including:! Service delivery! Financial management including budgetary review and opera3onal planning! Quality assessment and performance improvement ac3vi3es QAPI! Can be comprised of individuals chosen by the agency! Board members are accountable for ensuring that management and opera3on of the agency is effec3ve and within legal limits

30 Professional Advisory CommiYee! No longer required for the purpose of quarterly record reviews! Do not mistake this as an opportunity to lighten up on chart review and compliance monitoring! Agencies are required, based on the provisions of the ACA, to have Compliance Plans in place! Emphasis has shiled from the PAC to the Compliance rogram which is administered by the Governing Body

31 Administrator Du3es! Must be appointed by and report to the Governing Body! Is responsible for all day-to-day opera3ons! Must ensure that the clinical manager is available during opera3ng hours! Must ensure that qualified personnel are employed by the agency which means that agency staff have proper educa3on and creden3als

32 Administrator Qualifica3ons! Current administrators are grandfathered rela3ve to the qualifica3on requirements! An administrator hired following the effec3ve date must be a licensed physician, registered nurse or person with training and experience in health service administra3on with at least one year of supervisory experience and a minimum of an undergraduate degree

33 Administrator CMS Analysis and Comments! Can a single administrator oversee mul3ple agencies? Yes, but,! The administrator is expected to be available for all day-to-day opera3ons and for pa3ent s, representa3ves and caregivers to receive complaints! The administrator s ac3ve involvement in the agency s opera3ons must be demonstrated during surveys! CMS believes that ac3ve involvement in daily opera3ons and regular availability to pa3ents, caregivers, representa3ves and would be difficult if not impossible.. If the administrator is responsible for more than one agency on a given day

34 Alternate Administrators/Designees! The Governing Body is responsible for the appointment of the Administrator and should be similarly responsible for appointment of the designee who acts in the administrator s absence! During a survey, agency staff should know who the pre-designated individual(s) are for the role of administrator pro-tem! Alternate administrators must be qualified and appointed in wri3ng

35 Designees CMS Analysis and Comments! Designees would not be considered managing employees unless they act as the administratordesignee on a regular basis! If an alternate administrator does func3on in that capacity on a regular or scheduled basis, the agency may be required to disclose the designee as a managing employee

36 Clinical Manager! New role! Can be mul3ple individuals who are responsible for a group of pa3ents or specific du3es/responsibili3es related to coordina3on of pa3ent care! Must coordinate pa3ent care assignments and referrals! Assure that pa3ent needs are con3nually assessed and met! Assure that care plans are individualized and con3nually updated! Must be available during all opera3ng hours

37 Clinical Manager CMS Analysis and Comments! It may be rare for an individual to be able to serve as an administrator and clinical manager at the same 3me but the arrangement is not prohibited as long as quality of care is not compromised! Designees would not be considered managing employees unless they act as the administratordesignee on a regular basis, but if they do then the agency must disclose the designee as a managing employee

38 Parent Branch Rela3onships! Focus is on flexibility in management and structure along with accountability that assures pa3ent safety and high quality pa3ent care! Subunits are eliminated as of the effec3ve date! Subunits will be treated as fully qualified agencies, subject to survey unless the parent agency converts the subunit to a branch! Process for how that is done is not yet final

39 Subunits Outstanding Ques3ons Ques3ons will be addressed in Chapter 2 of the SOM at a future date 1. How will the transi3on occur for pa3ents that span the conversion? 2. Will subunits that are being converted be automa3cally recognized as parent agencies without a further applica3on or conversion process? 3. Will subunits conver3ng to branch status be treated as new enrollees?

40 Subunits Ques3ons cont. 4. Will a new Form 855A be required for subunit conversions? 5. Will converted subunits be subject to survey as a new HHA? 6. Will subunits be required to DC pa3ents and then readmit them to the parent? 7. Will billing and claim processing for subunits being converted be interrupted and, if so, how?

41 Subunits Ques3ons cont. 8. How will subunits being converted to branch offices be added to parent HHA CCNs? 9. If an 855A is required, will the process be streamlined if the agency s compliance record is posi3ve? 10. How will subunits undergoing the process to become branches be held accountable for data transmission, billing and compliance during the transi3on process?

42 Subunits CMS Analysis and Comments! Subunits are already the equivalent of stand-alone HHAs and will be able to con3nue func3oning as such, relieving the need to convert to a branch! There will be no change in the approval process or resource commitment of State Sas for branch approvals! CMS did reiterate that agencies will be able to convert subunits to branch status

43 Services Under Arrangement! Services provided by others must meet the requirements of the CoPs! Services under arrangement require wriyen agreements! Agency must maintain control

44 Services Under Arrangement CMS Analysis! CMS interpreta3on of direct service is unchanged and means services provided by an employed individual who receives a W-2 from the agency! Agencies may not use contracted individuals to provide direct services including those who are employed by PEOs or Professional Employer Organiza3ons! Agencies are s3ll obligated to ensure that contracted en33es are in good standing and not debarred

45 Ins3tu3onal Planning and Financial Management! There are no changes to these standards including those related to:! Development of the annual opera3ng budget! Development of the capital budget! Prepara3on of the annual plan! Approval of the annual plan by the Governing Body

46 Clinical Records Clinical Records! Agencies must maintain clinical records that contain past and current informa3on on every pa3ent! Informa3on must be accurate, adhere to documenta3on standards and be available to physicians issuing orders for care as well as agency staff

47 Clinical Records Assessments and Care Plans! The record must contain the current comprehensive assessment plus assessments from the most recent admission together with! Clinical notes! Plans of Care! Physician orders! Interven3ons including medica3on administra3on, treatments and services with the pa3ent s response to services! Goals together with documenta3on of pa3ent progress toward achievement of goals! Contact informa3on for the pa3ent, caregiver, physician including those who will provide post-discharge care

48 Discharge and Transfer Summaries! Discharge summaries must be prepared and sent to the physician or prac33oner who will provide post-discharge care within 5 business days of the home health discharge! A complete transfer summary must be sent within 2 days of a planned transfer and within 2 days of the agency s first knowledge of an unplanned transfer if the pa3ent is s3ll under care in a facility when the agency becomes aware of the transfer

49 CMS Analysis Discharge Summaries! Important for con3nuity of care and effec3ve transi3ons! Ideally, summaries should be prepared on the day of transfer or discharge and sent within 2 calendar days and CMS strongly encourages agencies to meet these 3meframes! The maximum limits are 2 business days for a transfer and 5 business days for a discharge! Agencies should be proac3ve with respect to summaries as CMS believes that pa3ents are benefiyed by 3mely exchange of informa3on

50 Authen3ca3on and Preserva3on! Clinical records must be retained for 5 years not new! Safeguards against loss or unauthorized use must be ins3tuted! Pa3ents must be able to receive their records without charge within 4 business days or at the next home visit, whichever comes first

51 Date and Time Entries! Clinical records must include the date and 3me of the event to reflect an accurate account of the course of care! Expecta3on is that the record will present a linear account of care that is delivered by the agency

52 Document Reten3on While we understand that HHAs may desire to destroy paper copies of signature documents in order to reduce physical paper storage space, we believe that maintaining the original, signed paper documents is essen3al for purposes of authen3ca3on of the documents.... HHAs bear ul3mate responsibility for con3nuous compliance with the requirements of these regula3ons... and are expected to manage all contracts... to assure compliance.

53 Personnel Qualifica3ons Personnel Qualifica3ons! Qualifica3ons of the administrator it was not our intent to disqualify currently employed administrators from con3nuing to perform their du3es to current employers, but the new requirements will extend to newly hired administrators aler the effec3ve date! No changes to other discipline requirements other than the clinical manager posi3on which is a new requirement

54 Clinical Manager Qualifica3ons! Licensed physician, physical therapist, speech-language pathologist, occupa3onal therapist, audiologist, social worker or a registered nurse! Must be capable of supervising mul3ple aspects of pa3ent care and individuals providing that care

55 Enter your questions in the chat window! JILL DYER BSN, RN, HCS-D, HCS-O Home Health Executive, Consultant J.I.D. Consulting SHARON HARDER President, C3 Advisors, LLC

56 Request a demo of the Kinnser solutions that will help your agency succeed kinnser.com/requestademo sales@kinnser.com