Hi,

I hope everyone had a great weekend! Below are a few follow up items from our meeting last week:

F2F:

I sent Shelly at NGS an email regarding this. Here is her response:

The regulations indicate that if the physician or allowed practitioner completing the face to face encounter and referring the patient for home health is an acute or post-acute care provider referring the patient to home health they may or may not be the certifying physician. For instance, a hospitalist would not be able to monitor home health services and would therefore identify the provider in the community who agrees to monitor home health… On the other hand, if there is a provider (MD, PA, NP for instance) who sees the patient in their office, completes a face to face encounter & refers the patient for home health – they should be the provider monitoring and certifying home health services as there would be no reason why they should be referring the patient to another provider.

The way I understand it, as nothing has changed. The regulations in chapter 7 of the Medicare Benefit Policy Manual have not changed. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c07.pdf

It seems CMS is aware that there is some confusion, and if there are any changes as a result of the inquiry the MACs will work on collaborative education surrounding the topic.

I will be working on a F2F guidance document in the next couple of weeks and will send it over to the group for review when ready!

State funded nurses:

Thank you again for bringing up the issue of agency nursing staff being hired for much higher rates for hospital decompression. As stated during our meeting, we brought this up with a few members of DHS and MDH. The state said they have 4 vendors and they have put in the temp agency contracts to hire outside of the current State providers. They did recognize that they are aware that this is not always happening and is an issue.

During a follow up, they told us that they will continue to stress to these agencies not to hire staff from local providers. They did inform us that the 200+/hour wage is not normal for the temp agencies to be hiring at. We learned that this was to fulfil a special in-patient wing.

With our current home care initiative we are working on with the state, they have confirmed that none of the staff they have ready for this (or will outsource) will be from any MN homecare agency.

Please reach out if you have any questions or concerns on this. We will continue to advocate for the temp agencies to not hire from current state providers.

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