10/4/2017. New Home Health & Hospice Agencies. Missouri Deemed Agencies as of 10/02/2017. Agencies Currently Pending Deemed Status.

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1 List three trends with the hospice industry in Missouri Identify several hot topics Missouri hospices need to add to their radar Discuss the bureau s clarification of frequently asked hospice questions Explain what hospices need to accomplish to achieve compliance with the Medicare emergency preparedness regulations Describe deficient practices most frequently identified during Missouri hospice surveys this year 1

2 New Home Health & Hospice Agencies Hospice Agencies Currently Pending Deemed Status Home Health Hospice ACHC CHAP TJC 60 Missouri Deemed Agencies as of 10/02/ Home Health Hospice 2

3 Home Health Agencies Closed Hospice Agencies Closed Agencies Agencies Agencies Agencies Agencies Agencies FFY FFY FFY Condition Level Deficiencies Condition Tags 37 Click here to download this powerpoint template : Floral Love Free Powerpoint Template For more : Free Powerpoint Backgrounds Page 9 3

4 Click here to download this powerpoint template : Floral Love Free Powerpoint Template For more : Free Powerpoint Backgrounds 0 Hospice Complaints FFY 2015 FFY 2016 FFY 2017 Unsubstantiated Substantiated Page 10 3 Hospice Surveys with Immediate Jeopardy Cited Hospice FFY 2015 FFY 2016 FFY

5 New Home Health/Hospice Aide Test (Effective January 13, 2018) New Long Term Care Regulations (Effective November 28, 2017) Enrollment-and- Certification/GuidanceforLawsAndRegulations/N ursing-homes.html Hospice Rule Revisions Surveyor Practices Per Missouri license rule (ML 133) at 19 CSR (1) (H) 3 and hospice policy/guidelines When clinically indicated During and after business hours Within one hour after need is identified 5

6 Must be provided by nurses employed by the hospice Hospice CoP on Core Services at Hospice must routinely provide all core services with direct employees including nursing triage Regulatory update from NHPCO (newsletter) Per federal State Operations Manual at SOM Chapter 2, 2082 and agency policy/ procedure SOM requirements for discharge for cause (DFC) Bureau of Home Care requests from hospice agency prior to DFC- with brief explanation of problem identified (date), initials of patient, actions taken to try to resolve, and final action (DFC) date to Bureau Talk newsletter web address (Click on Publications & select Summer 2017) Discharge for Cause send to: Hospice Questions call 573/

7 Hospice CFR Home Health CFR /CFR Appendix Z S&C ALL Enrollment-and- Certification/SurveyCertificationGenInfo/Downl oads/survey-and-cert-letter pdf Establishes national requirements for providers to: PLAN for both natural and man-made disasters COORDINATE with Federal, state, tribal, regional and local emergency preparedness systems 7

8 Must describe a comprehensive approach to meeting needs of staff and patients during an emergency or disaster Must coordinate with other healthcare facilities and the whole community Must be reviewed annually An Emergency Plan Policies and Procedures Communication Plan Training and Testing Does the plan include all of the required elements? Has the agency documented the annual review including the date of the review and any updates made to the plan based on the review? Did your agency document both a facility-based and community based risk assessment? - Agencies can rely on a community-based risk assessment developed by other entities. Note: The format you use for your emergency plan is up to your agency s discretion. 8

9 Did you use an all-hazard approach? Natural disasters prevalent in your geographic region -Wildfires, tornados, flooding, etc. Man-made disasters -Riots, terrorist attacks Facility-based disasters -Equipment and utility failures, cyber attack, etc. NOTE: Surveyors will interview leadership and ask which hazards were included, why they were included and how the risk assessment was conducted. Agencies are not expected to address every possible hazard but should choose a multitude of events/hazards most likely to occur in the surrounding area. What strategies do you have for addressing emergency events? Have you developed a staffing strategy? A surge capacity strategy? What kind of patient population do you have and which ones would be at risk? Are they inpatient or home patient? What are their unique vulnerabilities in the event of an emergency or disaster? Which patients have limited mobility? What services will your agency be able to provide in an emergency? How will your agency continue its operations? What will your delegation of authority and succession plan look like? -At a minimum, there should be one person who is authorized in writing to act in the absence of the administrator or a person legally responsible for the operations of the agency. 9

10 What is your agency s process for working with local, tribal, regional, federal and State emergency preparedness officials? You must document your efforts to contact these officials to engage in collaborative planning for an integrated emergency response. If your P&Ps align with the hazards within your agency s risk assessment and your agency s overall emergency preparedness plan, risk assessment and communication plan? If there is documentation to show the agency s P&Ps are reviewed and updated annually? NOTE: Requirements can differ for home health, hospice and inpatient hospices. CMS does not specify where the agency must have the P&Ps. However, you must be able to demonstrate compliance upon survey. How will your agency: Inform State and local officials of any on-duty staff or patients that they are unable to contact? Surveyors may interview a staff member or leadership and ask you to explain the procedures in place in the event you are unable to contact a staff member or patient. Follow up with staff and patients to determine services that are needed? Does your agency have: A plan to follow-up with off-duty staff? A contingency plan if staff are not able to report to duty -Will you utilize staff from other agencies, or state or federally designated health professionals? 10

11 Your procedure for informing state and local (emergency preparedness) officials about patients in need of evacuation? (This does not apply to inpatient hospices). When and how is this communicated? Does it include the clinical care needed for these patients? - Is the patient mobile? - What type of life-saving equipment does the patient require? - Is this equipment able to be transported? - Does the patient have special needs? Is there a system for medical documentation that preserves patient information and protects confidentiality and maintains availability of records? Are records secure and readily available to support continuity of care during an emergency? NOTE: This regulation does not supersede or take away any requirements found under the medical records regulations but rather, adds to such policies and procedures. Is there a provision for arrangements with other facilities/providers to receive patients in the event of limitation or cessation of operations in order to maintain continuity of services? - The surveyors will look for these arrangements to be in writing, such as Memorandums of Understanding (MOUs) and Transfer Agreements, in order to demonstrate compliance. 11

12 Coordination of patient care within the agency, across healthcare providers, with State and local public health departments and emergency management agencies and systems Your agency s annual review and updates Did the agency include primary and alternate means for communicating within the agency? - Communication within the agency (staff) - State & local public health departments - Emergency management agencies & systems Ex. If in a rural area with limited or no internet and phone connectivity what alternate means is available to alert local and State emergency officials? - Are there satellite phones, radios or short wave radios? - Are your alternate means for communicating compatible with other agencies and state and local officials with which you plan to communicate? Surveyors may ask to see the communications equipment/systems listed in the plan. Names and contact information for: Hospice employees Entities providing services under arrangement Patient s physicians Other hospices Contact information for Federal, State, tribal, regional, and local emergency preparedness staff and other sources of assistance? Surveyors will ask to see a list of these contacts with their contact information and will ask for verification the list has been reviewed and updated at least annually but also when appropriate all year long. 12

13 A method for sharing information and medical documentation for patients under the agency s care with other healthcare providers to maintain continuity of care? -While the regulation does not specify timelines for delivering patient care information, agency s are expected to provide the information with a timeframe that allows for effective patient treatment and continuity of care. A means for releasing the patient information to include the general condition and location of patients? Must be based on: Emergency plan Risk assessment Policies & Procedures Communication Plan Must be documented and reviewed and updated at least annually Staff training files contain documentation that will verify that all staff received initial and annual emergency preparedness training - Did all new employees receive the training during orientation, and did contracted staff receive training consistent with their roles? There is documentation confirming staff knowledge of the training - The means of determining this is up to the agency NOTE: Surveyors may interview staff to verify knowledge of emergency procedures. 13

14 Does the hospice periodically review and rehearse the emergency plan with hospice employees (including nonemployee staff)? If your agency has multiple locations, was the training provided at the employee s specific location? Full Scale Community-Based Exercise Typically involves multiple agencies, jurisdictions and disciplines performing functional or operational elements. Assesses a facility s functional capabilities by simulating a response to an emergency that would impact the agency s operations and its given community. Results in a broader community response during an emergency Smaller Community-based exercise Your agency conducts a smaller communitybased exercise that involves other nearby facilities (a LTC, local hospital, a home health agency, ESRD facility, etc.) Can minimize the financial impact of this Testing requirement Still advised to contact your local/state emergency officials and healthcare coalitions, where appropriate and offer them the opportunity to attend. 14

15 Individual Facility-based exercise Your agency only Must be able to demonstrate how you address any risk(s) identified in your risk assessment. Table-top exercise Includes a group discussion led by a facilitator Uses a narrated, clinically-relevant emergency scenario and a set of problem statements, directed messages, or prepared questions designed to challenge an emergency plan. Healthcare Coalitions (HCC s) Promotes partnerships between healthcare, public health, EMS and emergency management Are groups of individual health care and response organizations who collaborate to ensure each member has what it needs to respond to emergencies and planned events Plan and conduct coordinated exercises to assess the health care delivery systems readiness Serve as a conduit for broader community engagement and coordination prior to, during and after the full-scale community-based exercise. After Action Report (AAR) Developed as a result of a roundtable discussion that includes leadership, department leads and critical staff who can identify and document lessons learned. At a minimum should determine: - What was supposed to happen - What occurred - What went well - What the agency can do differently or improve upon - A plan with timeliness for incorporating necessary improvement 15

16 On an annual basis, your agency must do all of the following: Participate in a full scale exercise that is communitybased or when a community-based exercise is not accessible, an individual, facility-based exercise - If your agency experiences an actual natural or manmade emergency that requires activation of the emergency plan, the agency is exempt from engaging in a community-based or individual, facility-based fullscale exercise for 1 year following the onset of the actual event. Note: If your facility is unable to participate in a full scale exercise, the surveyors will look for documentation of the date, the personnel and the agency or healthcare coalition that you contacted and reason you were unable to participate. Conduct an additional exercise that includes, but not limited to: A second full-scale exercise that is communitybased or individual facility-based A tabletop exercise Analyze the agency s response to and maintain documentation of all drills, tabletop exercises and emergency events, and revise the agency s emergency plan as needed. Documentation of all the exercises performed Efforts to identify a full-scale community based exercise (If you didn t participate in one) The agency s analysis (After Action Report {AAR}) Agency s response to the exercises and how you have updated your program based on this analysis 16

17 The agency may choose to participate in the healthcare system s coordinated EP program It is not a requirement If the agency has opted to be part of its healthcare system s program, the agency must have documentation to confirm the following: (Surveyors will verify by asking to see documentation of its inclusion in the program) Documentation verifying your agency s involvement in the development of the program, the annual reviews and any updates Did the program take into consideration your agency s unique circumstances, population, etc. Surveyor will ask to see the entire integrated program (emergency plan, P&Ps, communication plan and the training & testing program) Regional Coalitions Region A: Charity Hunter, MARC (Mid-America Regional Council) Chunter@marc.org Region C: Dale Chambers, STARRS (St. Louis Regional Response System) Dale.Chambers@ewgateway.org All Other Regions: Jackie Gatz, MHA (Missouri Hospital Association ) JGatz@mhanet.com 17

18 OTHER RESOURCES for Hospice and Home Health Planning, Training, and Exercise Integrated Surveyor Training Website click on "I am a Provider." Other CMS resources FEMA.gov: Developing and Maintaining Emergency Operations Plans, Comprehensive Preparedness Guide (CPG) 101.v2 Nov National Assoc for Home Care & Hospice: Emergency Preparedness Packet for Home Health Agencies Maryland-National Capital Homecare Assoc Exercise tools 18