Right.

Paula Berger RN, PHN, COS-C

Regulatory Compliance Supervisor

Park Nicollet Methodist Home Care

W 952-993-3669 C 612-554-5802

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From: medicarewkgp@list.mnhomecare.org [mailto:medicarewkgp@list.mnhomecare.org] On Behalf Of Karen Peterson
Sent: Wednesday, May 27, 2020 1:20 PM
To: medicarewkgp@list.mnhomecare.org
Subject: [EXTERNAL]RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

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

OK!

See, all it took was for me to reach out to you all and I got the clarity I needed 😊.

Telehealth, when both audio and video, IS acceptable for F2F
You all are getting orders based on audio-only visits, which are NOT acceptable
Physicians/NPs/PAs are allowed to do SOME visits audio-only, so the ask to CMS is to expand that waiver to include F2F during the PHE.

Is that right?

I’ll get it to NAHC.

You all are terrific –

Karen

From: Troumbly, Katie J <ktroumb1@Fairview.org>
Sent: Wednesday, May 27, 2020 1:11 PM
To: Karen Peterson <kpeterson@mnhomecare.org>
Subject: RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

This is the information that I shared with our physicians…

COVID-19 Telehealth Expanded Options

Good news for physician appointments: CMS has announced a waiver to allow increased use of Telehealth. Physicians are now allowed to use telehealth for home care F2F and recerts, as long as they are using a connection with both audio and video. They may connect with patients who are in their private residence – allowing patients to stay home. In addition, HIPAA requirements are temporarily suspended, which allows for the use of private smart phones by either or both parties. The physicians will be able to receive the same reimbursement as if it were an office visit. Fact Sheet for this change is here; FAQ found here.

Thank you,

Katie

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Karen Peterson
Sent: Wednesday, May 27, 2020 9:38 AM
To: Rebekah Mattocks <Rebekah.Mattocks@knutenelson.org>; Berger, Paula <paula.berger@parknicollet.com>; Brand, Vickie (HealthEast) <vkbrand@healtheast.org>; medicarewkgp@list.mnhomecare.org
Subject: RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

Hey everyone –

Clearly this is a big issue and so I decided I better read up on it to make sure I was representing the challenge properly in my reply to NAHC.

What I found, however, is info that seems to indicate telehealth F2Fs should be acceptable during the PHE. This is in the grid provided by PQHH. When I click on the link, it refers to a general statement of physician services may be done by telehealth – neither specifically including or excluding F2F visits.

Face to face (F2F) via telehealth

· CMS has said that the F2F encounter can be performed via telehealth. Under the expansion of telehealth under the 1135 waiver, beneficiaries are able to use telehealth with their doctors and practitioners from home for the face-to-face encounter to qualify for Medicare home health care. COVID-19 FAQs updated 3/23/20.

· CMS should further clarify that audio telephonic communication from physicians also suffices for the F2F encounter requirement.

And then this is in a NAHC FAQ:

Q: Just to clarify : For the face to face by a physician to count for home health it must be audio and video?

A: Yes, the waiver permits a physician to conduct the F2F encounter visit via telehealth in the patient’s home. CMS requires that the visit be conducted by two-way audio-video communication.

So while there is a bit of disagreement between the two as to whether it can be done with just audio, they agree that telehealth F2F should be acceptable. Therefore I have concluded that I must be missing something – can one of you point out where F2F visits are excluded from the 1135 waiver? Since I am not up-to-speed in coding, I am suspecting it’s something to do with that …..

Thanks so much –

Karen

From: Rebekah Mattocks <Rebekah.Mattocks@knutenelson.org>
Sent: Wednesday, May 27, 2020 7:23 AM
To: Berger, Paula <paula.berger@parknicollet.com>; Brand, Vickie (HealthEast) <vkbrand@healtheast.org>; Karen Peterson <kpeterson@mnhomecare.org>; medicarewkgp@list.mnhomecare.org
Subject: RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

This has been a big issue for us as well. Many are coming through as just phone calls and we are having to jump through hoops. We’ve had to do several payor realignments because we weren’t able to get them in the 30 day period.

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Berger, Paula
Sent: Tuesday, May 26, 2020 4:42 PM
To: Brand, Vickie (HealthEast) <vkbrand@healtheast.org>; Karen Peterson <kpeterson@mnhomecare.org>; medicarewkgp@list.mnhomecare.org
Subject: RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

Agree 100%. We are getting more and more “telephone” face to face. This is very problematic.

Paula Berger RN, PHN, COS-C

Regulatory Compliance Supervisor

Park Nicollet Methodist Home Care

W 952-993-3669 C 612-554-5802

paula.berger@parknicollet.com

From: medicarewkgp@list.mnhomecare.org [mailto:medicarewkgp@list.mnhomecare.org] On Behalf Of Brand, Vickie (HealthEast)
Sent: Tuesday, May 26, 2020 4:28 PM
To: Karen Peterson <kpeterson@mnhomecare.org>; medicarewkgp@list.mnhomecare.org
Subject: [EXTERNAL]RE: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

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

I’m surprised that NAHC hasn’t advocated for HHA’s in this letter about allowing the f2f encounter visit to be telephonic. This is such a huge problem for us and the providers don’t understand why they can bill for a telephone visit, but home health can’t accept that as a valid f2f encounter visit.

I wonder if you could escalate this up to NAHC to see if they want to include it in their letter?

Thanks Karen!

Vickie Brand | BSN, RN, PHN

Compliance Program Director

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: Tuesday, May 26, 2020 3:26 PM
To: medicarewkgp@list.mnhomecare.org
Subject: FW: [Forum of States] March 30 Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

Greetings,

Attached (link at bottom) is the final draft of NAHC’s most recent proposal to CMS -- wanted to share it with you so you know shat is being advocated for, and if you have any comments or suggestions, feel free to share them with me and I will make sure NAHC hears about it prior to the June 1 deadline.

Karen Peterson

Regulatory Affairs and Advocacy Manager

Minnesota HomeCare Association

2550 University Ave. W., Ste. 350 S | St. Paul, MN 55114-1900

Direct: 651.659.1457 | Main: 651.635.0607

Toll-free: 866.607.0607 | Fax: 651.635.0043

www.mnhomecare.org | kpeterson@mnhomecare.org

Mission: MHCA represents and supports Minnesota home care providers committed to high quality home care services.

Vision: MHCA will shape the home care landscape to improve and sustain quality home care services.

From: Forum of States Discussion List
Sent: Tuesday, May 26, 2020 2:54 PM
Subject: Interim Final Rule -- DRAFT NAHC HOME HEALTH Comments

Hi, everyone. Attached are draft HOME HEALTH comments that Mary Carr has developed. Comments are due next Monday -- June 1.

File attachment: IFC-HH-comments-draft2.docx

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