Team,

Thank you for your response to the request for information. We have already sent in our information. I will continue to take these 1 by one and save them incase we are able to send in more responses.

Paulette

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Rachel Eastwood
Sent: Wednesday, April 23, 2025 9:47 AM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

I have one more that came up today. I think I am done sending these nowJ

Revise the recertification 5 day assessment window which is currently day 56-60 to a 7 day assessment window of 54-60 days. The 5 day window can pose challenges for both the agency and for patients as these visits can fall on days the agency doesn’t typically provide visits, making them non-billable for the agency and inconvenient for the patient. Most patients are seen at least weekly and a 7 day window would allow for easier tracking and the likelihood a the assessment would coincide with a regular scheduled visit (in cases where patients prefer this to occur).

Adds unnecessary cost for agency-non-billable visits

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Paulette Duncan
Sent: Tuesday, April 22, 2025 11:46 AM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

I will forward onto Kathy.

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Rachel Eastwood
Sent: Tuesday, April 22, 2025 9:45 AM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

If it isn’t too late- I have a few more J

CURRENT LIST:

Removal of the federal requirement of electronic visit verification for Medicaid patients who are receiving care provided by Medicare Certified, comprehensive licensed home care agencies. – Extreme administrative and financial burden to home care agencies that are already heavily governed by the Medicare CoPs and the state.

Has no clinical value
Doesn’t improve patient safety
Adds unnecessary costs

System cost if not using the state provided system, personal cost for managing the system, technology cost

Increases agency cherry picking referrals based on payer source (lower reimbursement for Medicaid and more overhead expense with EVV) = less access to care for Medicaid clients

Remove inability for Occupational Therapy to be a standalone, qualifying discipline for home health. OT is an essential service to assess safety and keep patients independent in their homes longer, avoiding more costly long-term care options and frequent hospitalizations. OT can already standalone once the initial certification is complete and can already perform the comprehensive assessment. The discipline is as able to qualify the patient for Medicare services as any other discipline.

Adds unnecessary costs
Doesn’t improve patient safety, could impact patient safety due to this service not being offered for those that need it as a stand alone service

Remove requirement that the same discipline must complete both the initial and comprehensive assessment. When nursing is ordered continue to require nursing to complete initial assessment and then allow any other discipline on the referral to complete the comprehensive assessment for home health admission. This would allow faster access to home care services for patients while the health care industry continues to deal with a nursing shortage.

Adds unnecessary costs
Doesn’t improve patient safety

Simplify OASIS data collection tool to decrease clinician burden

Start with removing Home Health OASIS Items:

M1800 ADL items where the GGs are addressing the same or similar function
Influenza and Covid vaccination questions
Redundant and in MICC
Has no clinical value

Update regulations to reimburse for telehealth home care visits – telehealth visits require staff resources and should be reimbursed under the home health and count towards LUPA threshold

Adds unnecessary costs
Increase in patient care- more incentive for agencies to utilize and invest in the service. Many are choosing not to with margins already being tight. HIPPA compliant solutions to offer telehealth are not free so the reimbursement would offer an incentive to start this service.

Update regulations to remove face to face requirement for home health certification

Adds unnecessary costs

OR create more flexibility within the regulation:

-Allow community referrals POC to be signed by more than the doc that referred to HC (ex- a physician they collaborate with on the client’s care, either at the same clinic or a different)

-Make telehealth encounters for f2f purposes a permanent regulation vs temporary

Removal of the Acceptance to Services policy requirement.

Agencies already assess their ability to accept services for each patient continuously with every referral they take and communicate the ability to deny/take referrals to the referral sources. The ability to take referrals fluctuates too frequently depending on the volume of referrals, staffing availability, etc. that the general posting of services is not able to be updated frequently enough to assist referral sources. Requiring that the company review the public facing information regarding limitations related to types of service, duration, or service frequency and make updates as services change adds no benefit as a company would not be able to change the public facing information often enough to make it beneficial.

This increases the cost for the agency without any benefit.

Home health aide supervision

-There are different requirements for HR purposes (the annual sup visit) and supervision of the client (based on skilled care and not skilled care). This gets burdensome on agencies to track and implement, when many aides work cases that are both skilled and non-skilled. Simplify this.

-Consider moving skilled HHA sup visits to 21 days vs 14 OR allowing all HHA sup visits to be conducted via telehealth or phone call (vs the one allowed on a rare circumstance)

-Non skilled HHA care requires semi-annual on-site direct supervision of EACH HHA on a client’s case. That could mean that some clients are getting 4-5 sup visits in a 6 month period, depending on the number of aides assigned to a client. Consider moving this to yearly and define what “each” means. Does this mean someone who is regularly scheduled to visit the client or a HHA that fills in once every 3 months for a shift.

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Paulette Duncan
Sent: Tuesday, April 22, 2025 9:19 AM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

Thanks everyone for comments, Kathy turned over our response to the alliance.

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Rachel Eastwood
Sent: Tuesday, April 22, 2025 9:12 AM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

Thoughts about these additions?:

Adding these two sentences (in red) to #2?

Remove inability for Occupational Therapy to be a standalone, qualifying discipline for home health. OT is an essential service to assess safety and keep patients independent in their homes longer, avoiding more costly long-term care options and frequent hospitalizations. OT can already standalone once the initial certification is complete and can already perform the comprehensive assessment. The discipline is as able to qualify the patient for Medicare services as any other discipline.

Adds unnecessary costs

Doesn’t improve patient safety

Adding #7: Removal of the Acceptance to Services policy requirement.

This increases the cost for the agency without any benefit.

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Barb Jezorski
Sent: Monday, April 21, 2025 3:56 PM
To: medicarewkgp@list.mnhomecare.org
Subject: RE: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

I also agree with the below

Barb Jezorski, RN, MSN | COO
3900 Northwoods Drive, #240, Arden Hills, MN 55112
P: 651.789.8774 | F: 651.633.7301
www.truhealthcare.com

Making a difference MATTERS.

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From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Kirchoff, Jessica L
Sent: Monday, April 21, 2025 4:07 AM
To: medicarewkgp@list.mnhomecare.org
Subject: [EXTERNAL] RE: [External Mail] Request for information on federal regulations

Hi Paulette!

This is what we shared with our regulatory team surrounding this RFI.

Removal of the federal requirement of electronic visit verification for Medicaid patients who are receiving care provided by Medicare Certified, comprehensive licensed home care agencies. – Extreme administrative and financial burden to home care agencies that are already heavily governed by the Medicare CoPs and the state.

Has no clinical value

Doesn’t improve patient safety

Adds unnecessary costs

Remove inability for Occupational Therapy to be a standalone, qualifying discipline for home health. OT is an essential service to assess safety and keep patients independent in their homes longer, avoiding more costly long-term care options and frequent hospitalizations. OT can already standalone once the initial certification is complete and can already perform the comprehensive assessment. The discipline is as able to qualify the patient for Medicare services as any other discipline.

Adds unnecessary costs

Doesn’t improve patient safety

Remove requirement that the same discipline must complete both the initial and comprehensive assessment. When nursing is ordered continue to require nursing to complete initial assessment and then allow any other discipline on the referral to complete the comprehensive assessment for home health admission. This would allow faster access to home care services for patients while the health care industry continues to deal with a nursing shortage.

Adds unnecessary costs

Doesn’t improve patient safety

Simplify OASIS data collection tool to decrease clinician burden

Start with removing Home Health OASIS Items:

i. M1800 ADL items where the GGs are addressing the same or similar function

ii. Influenza and Covid vaccination questions

Redundant

Has no clinical value

Update regulations to reimburse for telehealth home care visits – telehealth visits require staff resources and should be reimbursed under the home health and count towards LUPA threshold

Adds unnecessary costs

Update regulations to remove face to face requirement for home health certification

Adds unnecessary costs

Removal of the Acceptance to Services policy requirement.

This increases the cost for the agency without any benefit.

Jessica Kirchoff OTR/L, MBA

Manager, Quality & Compliance – Home Health

Allina Health Home Health • Allina Health Commons

Office Phone: 612-262-7734• Mobile 612-810-4420 • Fax: 612-262-7643

Mail Route 10733 • 2925 Chicago Avenue • Minneapolis, MN 55407

Jessica.kirchoff@allina.com

From: medicarewkgp@list.mnhomecare.org <medicarewkgp@list.mnhomecare.org> On Behalf Of Paulette Duncan
Sent: Sunday, April 20, 2025 7:04 PM
To: medicarewkgp@list.mnhomecare.org
Subject: [External Mail] Request for information on federal regulations

Team,

The Office of Management and Budget (OMB) has issued a Request for Information (RFI) seeking public input on federal regulations that may be overly burdensome or outdated. This is a key opportunity for the home care industry to speak up and influence future policy.

Does anyone want to give input to this?

Kind Regards,

Paulette Duncan, MSN, RN

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 | pduncan@mnhomecare.org

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