I think you guys nailed it! Agree with all comments.

Paula Berger RN, PHN, COS-C

Regulatory Compliance Supervisor

Park Nicollet Methodist Home Care

952-993-3669

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From: medicarewkgp@list.mnhomecare.org [mailto:medicarewkgp@list.mnhomecare.org] On Behalf Of Michelle Enger
Sent: Monday, December 30, 2019 8:24 AM
To: Brand, Vickie <vkbrand@healtheast.org>; Karen Peterson <kpeterson@mnhomecare.org>; 'medicarewkgp@list.mnhomecare.org' <medicarewkgp@list.mnhomecare.org>
Subject: [EXTERNAL] RE: MLN Connects® Special Edition for Thursday, December 26, 2019

External Email: Don't click links or attachments unless you trust the email.

Good Morning – Thanks Vickie - see comments below!

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Brand, Vickie
Sent: Monday, December 30, 2019 7:34 AM
To: Karen Peterson <kpeterson@mnhomecare.org>; 'medicarewkgp@list.mnhomecare.org' <medicarewkgp@list.mnhomecare.org>
Subject: RE: MLN Connects® Special Edition for Thursday, December 26, 2019

Karen-

Here are some of the talking points off the top of my head, but I haven’t really had time to think about more. If I come up with any more items, I’ll send your wayJ

First of all, are we asking CMS to allow NPP’s (non physician practitioners- CNP, CNS, PA) to sign orders OR certify home health, or both? Of course, the preference would be both J I agree – we need NPP to do both!
NP’s, but not PA’s, are allowed to practice independently in our state (and others). If a beneficiary has an NP as their primary provider, the home health agency needs to work with the clinic and the patient to identify a physician for that patient. Often times, this process leads to a delay in providing care, and in some instances, a patient cannot receive home care if the physician refuses to be the attending physician. Also, when a physician does agree to be the certifying physician for the patient, but they are not as familiar with the patient as the CNP is, the continuity of care for that patient is disrupted while the patient is receiving home care services because the CNP is not directing the cares. Truth!
In many other health care settings, a nurse practitioner and PA can be the attending provider- including hospice. Also very true! We need consistency with the rest of the American health systems. Very common to have a PA or NP as the PCP. CMS should encourage licensed professionals to work at the top of his/her license.
It is more cost effective to have nurse practitioners, rather than physicians, certify and write orders for home care patients. Yes
NP’s can perform a F2F assessment, but a physician has to certify that it took place. That is an illogical requirement and it can delay reimbursement to the home health agency. In some cases, this can also delay care to a patient. Also agree, and also may lead to denial of claim if the physician won’t certify that the F2F took place – pretty sure this has happened once or twice around here.

Vickie Brand | BSN, RN, PHN

Compliance Program Manager

Fairview Home Care & Hospice

2450 26^th Ave. South | Minneapolis, MN 55406

vkbrand@healtheast.org | www.fairview.org

Office: 612-728-2388

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Karen Peterson
Sent: Thursday, December 26, 2019 4:47 PM
To: 'medicarewkgp@list.mnhomecare.org' <medicarewkgp@list.mnhomecare.org>
Subject: FW: MLN Connects® Special Edition for Thursday, December 26, 2019

Hi Workgroup Members –

MHCA will submit a comment to CMS on our support of allowing APRNs and PAs to write home care orders. Kathy has asked that I coordinate with you, as representatives of the Medicare/CMS/NGS Workgroup, to write a draft comment letter, to make sure we hit all the salient points. I’d like to get the draft done by Friday January 3 so Kathy has time to review it, and then we are potentially going to ask some additional associations to sign on with us. It’s all due to CMS by 1/17.

Could you each send me a list of the key talking points that we would want to include, and I will massage them into a letter? I’ll send it back to you before giving it to Kathy …. So I guess I need your comments by end of day on the 2^nd so I can get the letter done by end of day on the 3^rd.

I know it’s not much time – I appreciate whatever you can offer!

Thanks,

Karen

From: National Government Services <doNotReply@email.ngsmedicare.com>
Sent: Thursday, December 26, 2019 2:31 PM
To: Karen Peterson <kpeterson@mnhomecare.org>
Subject: MLN Connects® Special Edition for Thursday, December 26, 2019

Feedback on Scope of Practice

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MLN Connects® Special Edition for Thursday, December 26, 2019

Feedback on Scope of Practice

The Centers for Medicare & Medicaid Services (CMS) is seeking additional input and recommendations regarding elimination of specific Medicare regulations that require more stringent supervision than existing state scope of practice laws, or that limit health professionals from practicing at the top of their license.

We are seeking additional feedback in response to part of the President’s Executive Order (EO) #13890 on Protecting and Improving Medicare for Our Nation’s Seniors. The EO specifically directs HHS to propose a number of reforms to the Medicare program, including ones that eliminate supervision and licensure requirements of the Medicare program that are more stringent than other applicable federal or state laws. These burdensome requirements ultimately limit healthcare professionals, including Physician Assistants (PAs) and Advanced Practice Registered Nurses (APRNs), from practicing at the top of their professional license.

In response to suggestions we have already received regarding supervision, scope of practice, and licensure requirements, CMS has made a number of regulatory changes in several payment rules, including the CY 2020 Physician Fee Schedule, Home Health, and Outpatient Prospective Payment System final rules. These changes include, but are not limited to: redefining physician supervision for services furnished by PAs, allowing therapist assistants to perform maintenance therapy under the Medicare home health benefit and reducing the minimum level of physician supervision required for all hospital outpatient therapeutic services.

We are proud of the work accomplished, and now we need your help in identifying additional Medicare regulations which contain more restrictive supervision requirements than existing state scope of practice laws, or which limit health professionals from practicing at the top of their license. If you submitted comments on these topics to our 2019 Request for Information on Reducing Administrative Burden to Put Patients over Paperwork, thank you! We are reviewing those submissions.

We welcome any additional recommendations. Please send your recommendations to PatientsOverPaperwork@cms.hhs.gov with the phrase “Scope of Practice” in the subject line by January 17, 2020.

We also continue to welcome your input on ways in which we can reduce unnecessary burden, increase efficiencies and improve the beneficiary experience, and request that input on such topics only be sent to this email address with the phrase “Scope of Practice” in the subject line if they relate to the specific areas in regulation which restrict non-physician providers from practicing to the full extent of their education and training.

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