I just added a couple comments in Vikings purple.

Thanks

Connie

-----Original Message-----
From: Stark, Jennifer <Jennifer.Stark@slhduluth.com>
To: 'medicarewkgp@list.mnhomecare.org' <medicarewkgp@list.mnhomecare.org>
Sent: Mon, Dec 30, 2019 10:09 am
Subject: RE: MLN Connects® Special Edition for Thursday, December 26, 2019

I agree with all the points mentioned below and added just a bit in green. Thanks

Jennifer Stark, RHIA

Health Information & Compliance Coordinator

Home Care & Hospice

220 North 6^th Ave. East | Duluth, MN 55805

Phone: 218.249.6147 | Fax: 218.249.6166

jennifer.stark@slhduluth.com

slhduluth.com

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; Karen Peterson; 'medicarewkgp@list.mnhomecare.org'
Subject: RE: MLN Connects® Special Edition for Thursday, December 26, 2019

EXTERNAL Alert: Email from EXTERNAL system. Phishing Warning. Never provide Username or Password.

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! 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 key point is the PCP. This is just going to be prevalent with the aging population. Many of our Medicare recipients will not have physicians as their PCP. The NP is the one who knows the patient best and should in charge of the home health POC., 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! Yes, we’ve had many MDs express frustration with this, mainly due to the fact they are not familiar with the patient and thus have to review information and collaborate with the NPP overseeing the patients care in order to sign off on orders and certification---very time consuming and costly for them!
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. Agreed! In Hospice, NPs have been able to act as the hospice attending physician since 2003, yet are still not able to certify the patients terminal diagnosis for hospice, or certify for home health services. APRNs should be able to certify patients for home health and for hospice. APRNs have been able to certify patients for post-hospital extended care services in SNFs since 1995, as well as other post-acute care and rehab services.
It is more cost effective to have nurse practitioners, rather than physicians, certify and write orders for home care patients. Yes Back in 2012, the AARP Public Policy Institute indicated that by allowing ARPNs to certify home health services, Medicare could see $129 to $309 million in cost savings over 10 years based on the 15 percent reduction in Medicare payment for services when billed by a non-physician provider(NPP). Allowing APRN and PAs to certify home health and hospice services would eliminate the need to obtain documentation from physicians for home care and hospice certifications and orders, which is a burdensome, expensive process for agencies. It would save time for providers by eliminating the need for a collaborating physician to be involved in a patient’s care that is overseen by a APRN, eliminating the physicians need to review patient information, collaborate with the APRN, provide and sign off on all orders and certifications.
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. The F2F requirement was implemented to combat Medicare payment fraud/overuse of home health and hospice when not medically necessary by ensuring provider involvement in care, meeting with patients in person to verify eligibility criteria. If an NPP can perform the home care F2F encounter, this should satisfy the intent of the requirement without having to communicate findings to a physician who may not be familiar with the patient simply to certify the patient for home health. The current requirement creates unnecessary work for physicians, which can cause delays in care. The same is also true for hospice. If a NP is authorized to perform the F2F encounter and act as the attending physician, they should be able to certify the patient for hospice services.
My understanding is that the AMA has opposed this in the past. Given everything above, I don't know why or if that is still true. I am assuming it is about the need for control. But if the POC is sent to the MD (no signature required), then the MD still has access to all the information and can step in to exert control if he/she deems it necessary.

You may want to refer to the Home Health Care Planning Improvement Act of 2019 bill (S.296) that was introduced to the Senate in January, which speaks to the need to allow NP, CNS, CNM, and PAs the ability to certify home health services to ensure timely access to care for Medicare beneficiaries. Corresponding bill H.R.2150 was introduced to the House in April.

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

Select this link to view email as a web page, go here.

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.

To unsubscribe from this list please go to http://archives.simplelists.com

CONFIDENTIALITY NOTICE: This message (including any attachments) may contain confidential client information. The information is intended only for the use of the individual or entity to whom it is addressed. If you're not the addressee or the employee or agent responsible to deliver this e-mail to its intended recipient, you are hereby notified that any review, use, dissemination, distribution, disclosure, copying or taking of any action in reliance on the contents of this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately, delete this message from your computer and ask your network administrator to delete it from any storage or back up files.

To unsubscribe from this list please go to http://archives.simplelists.com

This St. Luke's communication is intended for the use of the person or entity to whom it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this information is prohibited. If you have received this message in error, please notify sender immediately

To unsubscribe from this list please go to http://www.simplelists.com/confirm.php?u=UbmDoRx4u97vztKl5S1Exyjvc7TA9iC9