Home Health & Hospice Articles by Topic: Policies and Procedures

Create a clinical documentation improvement program to achieve PDGM success

• Homecare Direction, Issue 6, June 6, 2019

  Strong documentation is key in home health, and implementation of the Patient-Driven Groupings...

Take these crucial actions to ensure success during CMS' Review Choice Demo

• Homecare Direction, Issue 6, June 6, 2019

  Agencies seeking to pass CMS’ Review Choice Demonstration (RCD) with flying colors should...

Will the Home Health Payment Innovation Act of 2019 pass?

• Homecare Q&A, Issue 5, May 31, 2019

  There appears to be fairly strong support in the Congress to pass the bill.  

Why do agencies struggle on Home Health Compare with hospitalizations?

• Homecare Q&A, Issue 4, April 18, 2019

  You note agencies' struggles with hospitalizations.

Thoughts on CMS' proposed rule to alleviate burden and when it will be finalized?

• Homecare Q&A, Issue 4, April 18, 2019

  A couple years ago, the new administration came in with a desire to simplify life for providers.

In the coming year, how do you think survey targets will change?

• Homecare Q&A, Issue 4, April 18, 2019

  We’re going to keep seeing agencies cited for issues involving organization and...

Find the balance between preparing for PDGM and living in the current PPS world

• Homecare Direction, Issue 4, April 8, 2019

  While experts agree it’s important to start preparing now for the Patient-Driven Groupings...

Boost retention rates by having agency leaders analyze, improve culture

• Homecare Direction, Issue 4, April 8, 2019

  As the number of employees increased at Shanadoa Home Health in Bartlesville, Okla., Owner Shanda...

How can we keep our eyes on the ball on hospitalizations as we move to the next PIP?

• Homecare Q&A, Issue 3, March 22, 2019

  Root cause analysis still needs to be done at every hospital transfer because agencies will be able...

What are the most common, easily fixable issues you see when it comes to agencies with high hospitalization rates in home health?

• Homecare Q&A, Issue 3, March 22, 2019

  One is going to be the scheduling aspect. Getting out to the home within 24 to 48 hours is vital.

Must PIPs include a representative of all disciplines, a physician and a consumer like the PAC?

• Homecare Q&A, Issue 3, March 22, 2019

  The revised CoPs don't give specific protocols for what a PIP must look like.

Is the board responsible to sign off on all policies? 

• Homecare Q&A, Issue 3, March 22, 2019

  The Home Health Conditions of Participation (CoPs) require the governing body approve all policies...

How can I decrease the number of clinician missed visits? How do Medicare surveyors treat missed visits?

• Homecare Q&A, Issue 3, March 22, 2019

  Are the clinicians moving the visits to another day during the week?

CMS suppresses RAP payments for all new home health agencies nationwide

• Homecare Direction, Issue 3, March 6, 2019

  In the short term, a new MLN Matters article announcing CMS will suppress payments associated with...

Any advice for best practices to add emerging infectious diseases into emergency prep?

• Homecare Q&A, Issue 2, February 25, 2019

  You note that CMS is adding “emerging infectious diseases” to the current definition of...

We have an issue with M2003 (Medication follow-up).

• Homecare Q&A, Issue 2, February 25, 2019

  The quality measure “drug regimen review conducted with follow-up for identified...

When a patient signs a paper form (consent for care, AOB, ABN, etc.) are we required to keep the actual signed form if we have a picture of the signed form in our electronic medical record?

• Homecare Q&A, Issue 2, February 25, 2019

  When the revised Home Health Conditions of Participation (CoPs) originally came out, there was an...

In the QAPI requirement §484.65, what does CMS mean by including the prevention and reduction of medical errors?

• Homecare Q&A, Issue 2, February 25, 2019

  We are assessing and observing if we have an issue related to medical error.

If a MSW is ordered, but the case manager does not feel it is necessary, can she just not include it on the plan of care?

• Homecare Q&A, Issue 2, February 25, 2019

  Yes, it can be omitted from the plan of care.

For PDGM, agencies will need to change how they handle case conferencing

• Homecare Direction, Issue 2, February 5, 2019

  Case conferences will take on increased importance when the Patient-Driven Groupings Model (PDGM...

How should we speak with staff about shifting away from the pay-per visit model?

• Homecare Q&A, Issue 1, January 16, 2019

  You note that your agency is considering shifting away from a pay-per visit model for clinicians...

What is G1024 (Authentication) and how can agencies avoid getting cited for it?

• Homecare Q&A, Issue 1, January 16, 2019

   G1024 (Authentication) is one of the more common standard-level deficiencies in 2018.

Do agencies have a responsibility to train staff to identify whether patients are addicted to opioids?

• Homecare Q&A, Issue 1, January 16, 2019

  You asked whether agencies have a responsibility to train staff to identify whether patients are...

What's the best advice you have for an agency that hasn't been through a demonstration like the review choice demo before?

• Homecare Q&A, Issue 17, December 17, 2018

  Choose the pre-claim option.

What led Illinois agencies' improvement in the pre-claim demo?

• Homecare Q&A, Issue 17, December 17, 2018

  Learning and implementing the feedback loop.  

Do you see hospital-based agencies being more successful under PDGM?

• Homecare Q&A, Issue 17, December 17, 2018

  Hospital-based agencies are going to have more institutional admits than community admits.  

Where and how does value-based purchasing fit into PDGM?

• Homecare Q&A, Issue 17, December 17, 2018

  Home health value-based purchasing is a separate rewards system.  

Can you explain how partial episode payments (PEPs) will work under PDGM?

• Homecare Q&A, Issue 17, December 17, 2018

  First let’s go over how a PEP works.  

CMS gives itself one-year extension to publish a new discharge planning rule

• Homecare Direction, Issue 12, December 5, 2018

  CMS has just given itself an additional year — until Nov. 3, 2019 — to finalize its...

Our agency is considering investing in telehealth solutions. Do you have any recommendations for important questions to ask of potential vendors?

• Homecare Q&A, Issue 16, November 20, 2018

  Here are some of the questions to ask.  

For commercial payers, is it necessary to perform a recertification visit within the required five-day window?

• Homecare Q&A, Issue 16, November 20, 2018

  All payers must follow the Conditions of Participation, which require an update to the...

When it comes to the CoPs, what kinds of issues arise with policies?

• Homecare Q&A, Issue 16, November 20, 2018

  Often policies are written very well.

Do per-day sanctions begin when a surveyor finds a deficiency or do they begin on the date in the medical record when the deficiency occurred?

• Homecare Q&A, Issue 16, November 20, 2018

  I’ve seen it go both ways.

How do you expect enforcement from surveyors to change over the next year?

• Homecare Q&A, Issue 16, November 20, 2018

  It might not change. It might just intensify.

Improve your agency's efficiency by implementing quality cycle management

• Homecare Direction, Issue 11, November 5, 2018

  Establish procedures, set benchmarks and hold staff accountable to increase efficiencies as part...

What recommendations would you have when it comes to caring for patients who have lice or scabies?

• Homecare Q&A, Issue 15, October 19, 2018

  Staff should use contact precautions with a contact precaution kit. In general, wear protective...

What recommendations do you have when it comes to providing high-quality care to wound patients in a way that isn't expensive when it comes to supply costs?

• Homecare Q&A, Issue 15, October 19, 2018

  If agencies are spending a large amount on supplies for wound care patients, some suggestions to...

I saw that CMS recently posted an updated Public Use File (PUF). Could you explain why this is important and what it's for?

• Homecare Q&A, Issue 15, October 19, 2018

  The public use file is a file that is used by policymakers and researchers that review the...

Policies/procedures-volunteers and staffing [E-0024] is one of the most common standard-level deficiencies under the revised CoPs. Why?

• Homecare Q&A, Issue 15, October 19, 2018

  During an emergency, CMS has the expectation that agency staff should be able to assist in their...

If an RN discharges a patient early in the day, can another discipline make a visit as long as the visit is the same day?

• Homecare Q&A, Issue 15, October 19, 2018

  If the RN saw the client early in the day, another qualified discipline could see the client later...

Is a home health face-to-face visit required for Medicaid Advantage plans?

• Homecare Q&A, Issue 0, October 19, 2018

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Settlement reinforces need to act when ineligible care is alleged

• Homecare Direction, Issue 10, October 4, 2018

  Ensure sound protocols are in place for how to respond when an employee alerts you that your...

Is a home health face-to-face visit required for Medicare Advantage plans?

• Homecare Q&A, Issue 14, September 21, 2018

  CMS doesn't require Medicare Advantage plans to have a face-to-face document for home health.

In the following scenario, should my agency write an order stating the patient is in compliance of taking medications as ordered?

• Homecare Q&A, Issue 14, September 21, 2018

  In the scenario you describe, your agency admitted a patient when she was discharged home from the...

In this scenario, is my agency required to conduct a transfer then ROC, or not?

• Homecare Q&A, Issue 14, September 21, 2018

  In the scenario you discuss, your agency had a patient that was a full admission to the hospital.

If my agency makes drastic changes to adapt to PDGM, might CMS target us as though we're committing fraud?

• Homecare Q&A, Issue 14, September 21, 2018

  At this point, I would suggest you don't do anything drastic.

Explain CMS' moratoria for agencies in certain areas and how the demonstration recently changed.

• Homecare Q&A, Issue 14, September 21, 2018

  The demonstration gives an opportunity for providers and suppliers otherwise subject to the...

Is it legal to have one of our home health patients pay the same CNA privately on the days the patient is not being seen under the home health benefit?

• Homecare Q&A, Issue 13, September 4, 2018

  Does the patient require hours your agency is not providing, but should be?

Can you give pointers on "environmental cleaning and disinfection" as mentioned in draft guidelines for the revised CoPs?

• Homecare Q&A, Issue 13, September 4, 2018

  You should have a policy in place that describes things like a bag barrier and how to clean your...

What advice do you have about how an agency could improve when it comes to timely initiation of care?

• Homecare Q&A, Issue 13, September 4, 2018

  This is a difficult question to answer, not knowing your agency processes. But there are several...

Can you explain in this scenario whether our surveyor is correct and what our agency should do?

• Homecare Q&A, Issue 13, September 4, 2018

  In the scenario you discuss, your agency is in Indiana and are currently going through a federal...

What's an example of a billing aberrancy that's prompting contractors to target agencies in targeted probe-and-educate reviews?

• Homecare Q&A, Issue 12, July 25, 2018

  We see inappropriate recertifications all over the place.

Looking for some guidance on a patient with a closed stage IV pressure ulcer who now presents with non-blanchable redness to the same injury site but skin is intact.

• Homecare Q&A, Issue 12, July 25, 2018

  Once the wound is fully granulated and the wound surface is covered with epithelial tissue, the...

How should I act in the following scenario involving power of attorney (POA)?

• Homecare Q&A, Issue 12, July 25, 2018

  First determine if the POA is medical and if the patient is incapacitated.

Can advanced practice nurses (APNs) sign orders for home health patients?

• Homecare Q&A, Issue 12, July 25, 2018

  APRAs cannot write orders for a plan of care or subsequent verbal orders.

If a patient requires assistance to complete ADLs but is independent with all gait and mobility, can the person still be considered homebound per Medicare guidelines due to the taxing effort of getting ready to leave the home?

• Homecare Q&A, Issue 11, July 15, 2018

  This question cannot be answered, as each eligibility is established with each particular patient.

We have a policy that the patient must sign the tablet (EMR) post-visit. If a patient lives in an ALF and has dementia, is it OK to ask the patient to sign?

• Homecare Q&A, Issue 11, July 15, 2018

  There is no CMS regulation to have the EMR/tablet/daily visit record signed.

What if the PT and OT are ordered at SOC and the PT does an evaluation and no further treatments are ordered/planned but the OT does an eval and stays in alone for the episode?

• Homecare Q&A, Issue 11, July 15, 2018

  Per §1814(a)(2)(C) and §1835(a)(2)(A) of the Social Security Act, the patient must be in...

Our agency has had difficulty getting documentation for the F2F requirement from certain physicians. Should we deny the referrals?

• Homecare Q&A, Issue 11, July 15, 2018

  Denying a referral should be a determination based on agency policy and physician...

Review your emergency preparedness - it's a top target on surveys in 2018

• Homecare Direction, Issue 7, July 2, 2018

  Among the top 12 standard-level deficiencies in home health thus far in 2018, seven involve issues...

Is it OK to accept a doctor's signature on one page of a multi-page order as being signed?

• Homecare Q&A, Issue 10, June 11, 2018

  It is important for the pages of the plan of care to be clearly numbered if there is more than one...

Is it necessary to document the RVVO piece of a verbal order?

• Homecare Q&A, Issue 10, June 11, 2018

  The Joint Commission (TJC) includes a requirement under the Provision of Care, Treatment and...

Can we send an LPN to have consents signed and do wound care at SOC if the RN can’t come timely?

• Homecare Q&A, Issue 10, June 11, 2018

  PNs - along with occupational and physical therapy assistants - aren't qualified to establish the...

Say an agency is starting from scratch on the process of responding to ADRs. What is the first thing that should be put in place?

• Homecare Q&A, Issue 9, May 12, 2018

  First off, know on the front end that the biller is looking for those requested records. Ensure...

Do we need to enumerate one by one the patient?s rights over the phone to the legal representative?

• Homecare Q&A, Issue 9, May 12, 2018

  This can be done by electronic methods.

Do agencies have the right to tell patients we require a written request for patient records if the patient asks for a record over the phone?

• Homecare Q&A, Issue 9, May 12, 2018

  Agencies may require patients to make a written request for copies of the medical record. This is a...

For hospice, can activity done over the phone with a patient by a chaplain or social worker be considered a visit if the call is extensive and covers several items from the plan of care (POC)? What about for the purposes of meeting HIS quality measures?

• Homecare Q&A, Issue 8, April 17, 2018

  No conversation on the phone can be billable, as is the same for HIS quality measures.

How do we count the 14-day certified home health aide supervisory visit? Is the day of the visit day 1 or is the day after the visit day 1?

• Homecare Q&A, Issue 8, April 17, 2018

  The supervisory visits need to be no less frequently than every 14 days from the date of the first...

Train intake to gather more detail, ensure patient rights process is efficient

• Homecare Direction, Issue 4, April 12, 2018

  To help comply with the new patient rights requirements in the revised Home Health Conditions of...

Consider these 9 ways to avoid the hazards of an OSHA investigation

• Homecare Direction, Issue 3, March 26, 2018

  The lack of an appointed head of the Occupational Safe-ty and Health Administration (OSHA) has...

Improve on medication management in your performance improvement project

• Homecare Direction, Issue 3, March 12, 2018

  Agencies gearing up for the performance improvement project (PIP) requirement under the revised...

What data do we need to collect for QAPI?

• Homecare Q&A, Issue 2, January 17, 2018

  After defining the scope of an agency’s QAPI program, the CoPs outline how the quality...

Our agency looks at the PEPPER reports, but what pieces of information are most important?

• Homecare Q&A, Issue 2, January 17, 2018

  Note PEPPER’s six target areas: Average case mix. This target area calculates average case...

Prepare for new CoPs: Draft interpretive guidelines for the CoPs answer some questions, create others

• Homecare Direction, Issue 12, December 11, 2017

  CMS’ long-awaited draft version of the interpretive guidelines for the revised Home Health...

We are creating CDI policies. What should we include?

• Homecare Q&A, Issue 22, November 17, 2017

  The CDI department should have its own set of policies and procedures to govern its...

New low-volume option could shrink the line of appeals at the ALJ level

• Homecare E-News, Issue 43, November 13, 2017

  Home health agencies and other providers with a low volume of pending appeals at the administrative...

What procedures are we required to have?

• Homecare Q&A, Issue 20, October 17, 2017

  Procedures are detailed descriptions of the tasks required to implement and maintain agency...

Do we need clinical staffing benchmarks?

• Homecare Q&A, Issue 20, October 17, 2017

  Agencies must identify not only the appropriate compensation for staff but also the...

How can we use electronic clinical pathways to improve outcomes?

• Homecare Q&A, Issue 20, October 17, 2017

  Consider adopting clinical pathways to increase nursing visit efficiency, decrease...

Where is it specifically written that an NP or a PA cannot sign homecare orders?

• Homecare Q&A, Issue 20, October 17, 2017

  There is no language specifically stating an NP or PA cannot give orders. Rather, the rules...

What kind of personnel policies should we have?

• Homecare Q&A, Issue 18, September 19, 2017

   Some example of areas that an agency’s personnel policies should address are:

What should we do to better handle Additional Development Requests (ADR)?

• Homecare Q&A, Issue 18, September 19, 2017

  Here’s how to improve on ADRs:

Tip: Follow policy on staff discipline and discharge

• Homecare E-News, Issue 35, September 18, 2017

  The agency’s policies and procedures will include a discipline and discharge policy. It is...

What should our agency be aware of during hurricane season?

• Homecare Q&A, Issue 18, September 17, 2017

  Excellent question, given the active season we’ve been having. You must comply with...

Staff trainer quiz

• Homecare Direction, Issue 8, August 25, 2017

  1. Why is it important to practice infection control?

Staff trainer: Stop the spread

• Homecare Direction, Issue 8, August 25, 2017

  As an HHA staffer or nurse, you care for people in vital ways—bathing, grooming, feeding...

What does a psychosocial assessment need to include?

• Homecare Q&A, Issue 14, July 17, 2017

   The CoPs make clear that the plan of care will continue to be based on the comprehensive...

When we enter our discharge reason for home health, is it that the patient was transferred to an inpatient facility, or is the discharge reason that the patient expired?

• Homecare Q&A, Issue 16, August 22, 2016

  When our patients are admitted to an inpatient facility and we complete a transfer OASIS, we...

What advice do you have regarding policies in homecare agencies? We are reviewing ours and aren't sure if we should have more or less.

• Homecare Q&A, Issue 11, June 3, 2016

  First and foremost, a policy and a procedure are two entirely different animals. A policy is...

Discharge or hold for holiday vacation?

• Homecare Q&A, Issue 2, January 18, 2016

  We have a patient that meets Medicare eligibility for home health services, remains homebound, and...

Inside Story | Cerebrovascular disease (stroke) care

• Homecare E-News, Issue 2, January 11, 2016

  When working with stroke patients, you are responsible for several types of observations. First...

How can we document to support supply utilization and payment?

• Homecare Q&A, Issue 23, December 4, 2015

  Documentation will be important to support supply utilization and payment. Claims must include...

What content would be in a best practice statement for homecare providers?

• Homecare Q&A, Issue 23, December 4, 2015

  Best practice should identify clinical actions—assessment, teaching, procedures...

What policies do we need, and which additional policies should we have?

• Homecare Q&A, Issue 22, November 17, 2015

  What policies do we need, and which additional policies should we have?

Is there a guideline regarding the frequency of visits for psychiatric patients?

• Homecare Q&A, Issue 21, November 3, 2015

  Establishing a frequency is considered very unique, as a psychiatric patient sometimes requires the...

The Inside Story | Staff education on infection control

• Homecare E-News, Issue 40, October 19, 2015

  Care delivered according to infection control guidelines is the most effective tool available for...

In focus | NAHC submits comments on face-to-face clinical templates

• Homecare E-News, Issue 41, October 19, 2015

  Last Tuesday, NAHC submitted official comments to CMS on a pair of proposed clinical templates (one...

What are some approaches patients may try to implement themselves to overcome swallowing difficulties, and what are more effective alternatives?

• Homecare Q&A, Issue 20, October 16, 2015

  What are some approaches patients may try to implement themselves to overcome swallowing...

In focus | NAHC summarizes latest developments on the face-to-face reform front

• Homecare E-News, Issue 40, October 12, 2015

  While awaiting an imminent decision in its lawsuit challenging the validity of the physician...

Do regulations mandate any particular form or format for documentation or confirmation of verbal orders?

• Homecare Q&A, Issue 17, September 8, 2015

  No. The regulations do not mandate any particular form or format for documentation or confirmation...

How are we supposed to use observation and assessment for patients on telemonitoring?

• Homecare Q&A, Issue 15, August 3, 2015

  Telemonitoring or telehealth is one technology that can help a patient in the home. It cannot...

What content would be in a best practice statement for homecare providers?

• Homecare Q&A, Issue 13, July 2, 2015

  AA best practice should identify clinical actions—assessment, teaching, procedures...

Should there be one signature per order, or can orders be batch signed?

• Homecare Q&A, Issue 13, July 2, 2015

  As long as the order is a complete order for a treatment or therapy, you may have more than one...

Homecare Q&A

• Homecare Q&A, Issue 13, July 2, 2015

  July 3, 2015

Can we use standing orders for many of our specialty programs, like wound care?

• Homecare Q&A, Issue 11, June 3, 2015

  Can we use standing orders for many of our specialty programs, like wound care?

Can we accept orders from a physician?s secretary or office nurse who is communicating with us instead of the physician?

• Homecare Q&A, Issue 11, June 3, 2015

  Can we accept orders from a physician’s secretary or office nurse who is communicating with...

What should you do about a tardy recertification assessment?

• Homecare Q&A, Issue 10, May 17, 2015

  What should you do about a tardy recertification assessment?

Any tips for preventing future legal fallout in such cases?

• Homecare Q&A, Issue 7, April 3, 2015

  Unfortunately, when a fall occurs in the presence of agency staff, people assume that it...

How do I ensure each care team is led appropriately by the case manager?

• Homecare Q&A, Issue 6, March 17, 2015

  Effective teams need leadership. By using the term “case manager,” the home health...

How do you encourage reporting and open communication?

• Homecare Q&A, Issue 6, March 17, 2015

  What you are looking for is a nonpunitive, “just” culture for your agency, or a...

How can I ensure more effective meetings at our agency?

• Homecare Q&A, Issue 5, March 3, 2015

  We spend a tremendous amount of time in meetings. Many of them are boring, nonproductive, and...

Is there a requirement to have our annual program review/PAC minutes approved by our board of directors each year?

• Homecare Q&A, Issue 5, March 3, 2015

  There is not a specific Condition of Participation (CoP) stating that the board must review your...

Will home health remain exempt from overtime compensation in most circumstances like it has for 40 years?

• Homecare Insider, Issue 1, January 5, 2015

  Will home health remain exempt from overtime compensation in most circumstances like it has for 40...