Hi,
Below is the draft for the informer. Please let me know if anything should be changed.
Thanks!
Medicare Workgroup- HH Final Rule Clarification for HHA Supervision
The new requirement in
42 CFR 484.80(h)(2) CoPs states
that the RN must make a semi-annual visit to the location where the patient is receiving this care with the home health aide present (for non-skilled service episodes). The Medicare Workgroup had two questions on this and reached out to NAHC for clarification:
Q: If that patient has multiple aides that assist in their care, does each aide need to have a supervisory visit for that patient semi-annually?
A: Yes, each aide on the case needs to have a visit with that patient semi-annually. This could mean that some aides have many supervisory visits throughout the year, depending on their case load.
Q: Sometimes a home health aide visits a client to “fill in” for a regularly scheduled aide. Do those aides need to have a supervisory visit? If so, how would you suggest implementing this since sometimes they only
visit that patient once?
A: This is a question that NAHC has out for CMS to clarify. It is not clear in the CoPs how compliance for this will be assessed. Until then, NAHC’s recommendation was to have a supervisory visit at the first visit
of every “fill in” home health aide (noting that this is the most conservative approach and that this would be an extremely difficult thing to comply with). They did state that if you did not follow this approach and were cited, you could argue that there
was no clear guidance in the CoPs as to how compliance would be assessed.
Brianna Lindell
Regulatory Affairs Manager
Minnesota Home Care Association
1265 Grey Fox Road, Suite 2 | Arden Hills, MN 55112-6929
Direct: 651.240.3380 | Main:
651.635.0607
www.mnhomecare.org
|
blindell@mnhomecare.org
From: Brianna Lindell
Sent: Monday, December 6, 2021 8:30 AM
To: medicarewkgp@list.mnhomecare.org
Subject: FW: Final Rule clarification for MN homecare
Hi all,
Happy Monday!
Please see below for clarification on the HHA sup visit question that came up last week.
I will get something drafted for the informer.
Would someone be willing to review it to make sure I capture everything correctly?
Thanks!
Brianna Lindell
Regulatory Affairs Manager
Minnesota Home Care Association
1265 Grey Fox Road, Suite 2 | Arden Hills, MN 55112-6929
Direct: 651.240.3380 | Main:
651.635.0607
www.mnhomecare.org
|
blindell@mnhomecare.org
From: Katie Wehri <katie@nahc.org>
Sent: Monday, December 6, 2021 8:23 AM
To: Brianna Lindell <blindell@mnhomecare.org>
Subject: RE: Final Rule clarification for MN homecare
That is the most conservative response at this time, and what I would recommend. If an agency happens to get sited for a deficiency on survey because of this, though, I would argue it the other way – stating that there is not clear guidance
on how compliance is to be assessed – too many questions, i.e. how to handle patients that have aide services but are only on service a short time such as a week. This is nearly impossible to comply with operationally. But, yes, what you have stated is what
we would recommend.
Hope this helps.
Katie Wehri
Director of Home Health & Hospice Regulatory Affairs
National Association for Home Care & Hospice
202-547-7424
From: Brianna Lindell <blindell@mnhomecare.org>
Sent: Monday, December 6, 2021 8:33 AM
To: Katie Wehri <katie@nahc.org>
Subject: Re: Final Rule clarification for MN homecare
No worries, thank you for the answer!
So what is your advice for agencies while we wait for clarification? Do you suggest that if they have a fill in aide that goes out once, they should also send an RN to complete the sup visit at the time of that visit?
Brianna Lindell
Regulatory Affairs Manager
Minnesota Home Care Association
1265 Grey Fox Road, Suite 2 | Arden Hills, MN 55112-6929
Direct: 651.240.3380 | Main:
651.635.0607
www.mnhomecare.org
|
blindell@mnhomecare.org
From: Katie Wehri <katie@nahc.org>
Sent: Friday, December 3, 2021 4:50:09 PM
To: Brianna Lindell <blindell@mnhomecare.org>
Subject: RE: Final Rule clarification for MN homecare
Brianna,
Sorry for the delay in responding. Just realized I opened your email but did not answer it.
This is a great question that we have for CMS. It In general, I would say that this is going to apply to any aide – fill in or not. It isn’t clear from the final rule exactly how compliance will be assessed, and we are trying to get
more information. We will put an article in NAHC Report when we do.
Katie Wehri
Director of Home Health & Hospice Regulatory Affairs
National Association for Home Care & Hospice
202-547-7424
From: Brianna Lindell <blindell@mnhomecare.org>
Sent: Wednesday, December 1, 2021 10:52 AM
To: Katie Wehri <katie@nahc.org>
Subject: Final Rule clarification for MN homecare
Hi Katie!
I am hoping you can help me with some clarification on something in the final rule.
In reviewing the new supervisory requirements for unskilled patients, it is clear that all aides on a case will need to have the visit every 6 months. A question came up in regards to a “fill-in” aide. So if there is an aide that makes
a one time (or a few times) visit to the patient that they do not see on a regular basis, would that aide need to have a supervisory visit for that patient?
Any insight you can provide would be greatly appreciated!
Best regards,
Brianna Lindell
Regulatory Affairs Manager
Minnesota Home Care Association
1265 Grey Fox Road, Suite 2 | Arden Hills, MN 55112-6929
Direct: 651.240.3380 | Main:
651.635.0607
www.mnhomecare.org
|
blindell@mnhomecare.org