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Monday, May 11, 2020

changes to CMS rules for Hospice compliance in the aftermath of covid-19

Hospice: CMS Flexibilities to Fight COVID-19 

Since the beginning of the COVID-19 Public Health Emergency, the Trump Administration has issued an unprecedented array of temporary regulatory waivers and new rules to equip the American healthcare system with maximum flexibility to respond to the 2019 Novel Coronavirus (COVID-19) pandemic. These temporary changes will apply immediately across the entire U.S. healthcare system for the duration of the emergency declaration. 

The goals of these actions are to 1) expand the healthcare system workforce by removing barriers for physicians, nurses, and other clinicians to be readily hired from the community or from other states; 2) ensure that local hospitals and health systems have the capacity to handle a potential surge of COVID-19 patients through temporary expansion sites (also known as CMS Hospital Without Walls); 3) increase access to telehealth in Medicare to ensure patients have access to physicians and other clinicians while keeping patients safe at home; 4) expand in-place testing to allow for more testing at home or in community based settings; and 5) put Patients Over Paperwork to give temporary relief from many paperwork, reporting and audit requirements so providers, health care facilities, Medicare Advantage and Part D plans, and States can focus on providing needed care to Medicare and Medicaid beneficiaries affected by COVID-19. Medicare Telehealth and Telecommunications Technology • Hospice providers can provide services to a Medicare patient receiving routine home care through telecommunications technology (e.g., remote patient monitoring; telephone calls (audio only and TTY); and 2-way audio-video technology), if it is feasible and appropriate to do so. Only in-person visits are to be recorded on the hospice claim. • Face-to-face encounters for purposes of patient recertification for the Medicare hospice benefit can now be conducted via telehealth (i.e., 2-way audio-video telecommunications technology that allows for real-time interaction between the hospice physician/hospice nurse practitioner and the patient). Workforce • Training and Assessment of Aides: CMS is waiving the requirement at 42 CFR §418.76(h)(2) for Hospice and 42 CFR §484.80(h)(1)(iii) for HHAs, which require a registered nurse, or in the case of an HHA a registered nurse or other appropriate skilled professional (physical therapist/occupational therapist, speech language pathologist) to make an annual onsite supervisory visit (direct observation) for each aide that provides services on behalf of the agency. In accordance with section 1135(b)(5) of the Act, we are postponing completion of these visits. All postponed onsite assessments must be completed by these professionals no later than 60 days after the expiration of the PHE. • Annual Training. CMS is modifying the requirement at 42 CFR §418.100(g)(3), which requires hospices to annually assess the skills and competence of all individuals 1 04/29/2020 furnishing care and provide in-service training and education programs where required. Pursuant to section 1135(b)(5) of the Act, we are postponing the deadline for completing this requirement throughout the COVID-19 PHE until the end of the first full quarter after the declaration of the PHE concludes. This does not alter the minimum personnel requirements at 42 CFR §418.114. Selected hospice staff must complete training and have their competency evaluated in accordance with unwaived provisions of 42 CFR Part 418. • Quality Assurance and Performance Improvement (QAPI). CMS is modifying the requirement at 42 CFR §418.58 for Hospice and §484.65 for HHAs, which requires these providers to develop, implement, evaluate, and maintain an effective, ongoing, hospice/HHA-wide, data-driven QAPI program. Specifically, CMS is modifying the requirements at §418.58(a)–(d) and §484.65(a)–(d) to narrow the scope of the QAPI program to concentrate on infection control issues, while retaining the requirement that remaining activities should continue to focus on adverse events. This modification decreases burden associated with the development and maintenance of a broad-based QAPI program, allowing the providers to focus efforts on aspects of care delivery most closely associated with COVID-19 and tracking adverse events during the PHE. The requirement that HHAs and hospices maintain an effective, ongoing, agency-wide, datadriven quality assessment and performance improvement program will remain. • Waive requirement for hospices to use volunteers. CMS is waiving the requirement at 42 CFR §418.78(e) that hospices are required to use volunteers (including at least 5% of patient care hours). It is anticipated that hospice volunteer availability and use will be reduced related to COVID-19 surge and anticipated quarantine. • Waived onsite visits for Hospice Aide Supervision: CMS is waiving the requirements at 42 CFR 418.76(h), which require a nurse to conduct an onsite visit every two weeks. This would include waiving the requirements for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan, as this may not be physically possible for a period of time. Patients Over Paperwork • Comprehensive Assessments: CMS is waiving certain requirements for Hospice 42 CFR §418.54 related to update of the comprehensive assessments of patients. This waiver applies the timeframes for updates to the comprehensive assessment (§418.54(d)). Hospices must continue to complete the required assessments and updates, however, the timeframes for updating the assessment may be extended from 15 to 21 days. • Waive Non-Core Services: CMS is waiving the requirement for hospices to provide certain non-core hospice services during the national emergency, including the requirements at 42 CFR §418.72 for physical therapy, occupational therapy, and speechlanguage pathology. 2 04/29/2020 • Accelerated/Advance Payments: In order to provide additional cash flow to healthcare providers and suppliers impacted by COVID-19, CMS expanded and streamlined the Accelerated and Advance Payments Program, which provided conditional partial payments to providers and suppliers to address disruptions in claims submission and/or claims processing subject to applicable safeguards for fraud, waste and abuse. Under this program, CMS made successful payment of over $100 billion to healthcare providers and suppliers. As of April 26, 2020, CMS is reevaluating all pending and new applications for the Accelerated Payment Program and has suspended the Advance Payment Program, in light of direct payments made available through the Department of Health & Human Services’ (HHS) Provider Relief Fund. Distributions made through the Provider Relief Fund do not need to be repaid. For providers and suppliers who have received accelerated or advance payments related to the COVID-19 Public Health Emergency, CMS will not pursue recovery of these payments until 120 days after the date of payment issuance. Providers and suppliers with questions regarding the repayment of their accelerated or advance payment(s) should contact their appropriate Medicare Administrative Contractor (MAC). Medicare appeals in Fee for Service, Medicare Advantage (MA) and Part D • CMS is allowing Medicare Administrative Contractors (MACs) and Qualified Independent Contractor (QICs) in the FFS program 42 CFR 405.942 and 42 CFR 405.962 and MA and Part D plans, as well as the Part C and Part D Independent Review Entity (IREs), 42 CFR 562, 42 CFR 423.562, 42 CFR 422.582 and 42 CFR 423.582 to allow extensions to file an appeal; • CMS is allowing MACs and QICs in the FFS program 42 CFR 405. 950 and 42 CFR 405.966 and the Part C and Part D IREs to waive requirements for timeliness for requests for additional information to adjudicate appeals; MA plans may extend the timeframe to adjudicate organization determinations and reconsiderations for medical items and services (but not Part B drugs) by up to 14 calendar days if: the enrollee requests the extension; the extension is justified and in the enrollee's interest due to the need for additional medical evidence from a noncontract provider that may change an MA organization's decision to deny an item or service; or, the extension is justified due to extraordinary, exigent, or other non-routine circumstances and is in the enrollee's interest 42 CFR § 422.568(b)(1)(i), § 422.572(b)(1) and § 422.590(f)(1); • CMS is allowing MACs and QICs in the FFS program 42 C.F.R 405.910 and MA and Part D plans, as well as the Part C and Part D IREs to process an appeal even with incomplete Appointment of Representation forms 42 CFR § 422.561, 42 CFR § 423.560. However, any communications will only be sent to the beneficiary; • CMS is allowing MACs and QICs in the FFS program 42 CFR 405. 950 and 42 CFR 405.966 and MA and Part D plans, as well as the Part C and Part D IREs to process requests for 3 04/29/2020 appeal that don’t meet the required elements using information that is available 42 CFR § 422.562, 42 CFR § 423.562. • CMS is allowing MACs and QICs in the FFS program 42 CFR 405. 950 and 42 CFR 405.966 and MA and Part D plans, as well as the Part C and Part D IREs, 42 CFR 422.562, 42 CFR 423.562 to utilize all flexibilities available in the appeal process as if good cause requirements are satisfied. • Cost Reporting. CMS is delaying the filing deadline of certain cost report due dates due to the COVID-19 outbreak. We are currently authorizing delay for the following fiscal year end (FYE) dates. CMS will delay the filing deadline of FYE 10/31/2019 cost reports due by March 31, 2020 and FYE 11/30/2019 cost reports due by April 30, 2020. The extended cost report due dates for these October and November FYEs will be June 30, 2020. CMS will also delay the filing deadline of the FYE 12/31/2019 cost reports due by May 31, 2020. The extended cost report due date for FYE 12/31/2019 will be July 31, 2020. Additional Guidance • The Interim Final Rules and waivers can be found at: . • CMS has released guidance to describe standards of practice for infection control and prevention of COVID-19 in hospices at hospice.pdf • CMS has released guidance to providers related to relaxed reporting requirements for quality reporting programs at

Tuesday, September 3, 2019

Nervous about your upcoming survey? Try these pointers to ease your anxiety. Hospice Readiness Helpful Hints to reduce your fear and dread!

For Survey have these available in a binder: ♣ Organizational chart ♣ Unduplicated admissions number for previous 12 months ♣ Current census, live discharges, revocations, deaths/bereavement ♣ Current schedule of visits ♣ Personnel list, volunteers, contract staff ♣ Contracts for Therapy ♣ Contracts for Medical Director/Alternate Medical Director ♣ Contracts for SNF/orientation to SNF staff ♣ Contracts for inpatient care ♣ Contracts for pharmacy ♣ Contracts for DME ♣ Admission packet ♣ Patient education materials ♣ Volunteer Program information ♣ Cost savings ♣ Activity level ♣ Governing Body members & meeting minutes ♣ QAPI activities and initiatives ♣ Current Hospice License ♣ CLIA waiver, if applicable ♣ Complaint/Grievance logs ♣ Incident reports
Have Staff Files pulled and ready for review with these areas Identified in the file: ♣ Review personnel records for key staff, contract staff, and volunteers ♣ Verification of qualifications ♣ Orientation records, competencies ♣ Background checks ♣ Based on unduplicated admissions ♣ Representative of the care provided ♣ Pediatric-geriatric ♣ Environment served ♣ Medically complex Unduplicated Admissions For a recent 12 months Minimum # of Record Reviews Without Home Visit Minimum # of Record Reviews With Home Visit Total Record Reviews <150 admission is 8 no home visit, 3 with 150-750 admissions is 10 no home and 3 home visits, 751-120 is 15 no home and 5 home visits
Get the family and the patient ready for home visit: Prepare patients and families ♣ Explain the intent of the visit ♣ Ask the surveyor how consent is demonstrated ♣ Common questions asked of the patient: ♣ Do you know how to reach your hospice after hours? ♣ Who comes to visit you? ♣ Have you had for services, medications, equipment? ♣ Have you had a time where you were in pain and couldn’t get the hospice to respond? ♣ Do you know how to file a complaint about the hospice And Staff: ♣ Prepare staff ♣ Observe ♣ Ensure staff are providing care according to agency policies and procedures ♣ Infection control ♣ Following the Plan of Care ♣ Desensitize staff to being observed Assess staff knowledge of: ♣ Policies and procedures ♣ Medicare Conditions of Participation ♣ State hospice regulations ♣ Practice act/scope of practice ♣ Comprehension of knowledge ♣ Competency ♣ Application of knowledge ♣ Observe on home visits ♣ Review post visit documentation
These are the top problematic deficiencies that are seen in the past six months of audits: ♣ 418.54 Initial and Comprehensive Assessment ♣ L523 Timeframe for Completion of Assessment ♣ L530 Content of Comprehensive Assessment • Drug profile/review ♣ L533 Update of Comprehensive Assessment 418.56 Interdisciplinary Group, Care Planning and Coordination of Services ♣ L538 POC specified care/services to meet the needs of the patient/family ♣ L543 Plan of care ♣ L545 Content of the plan of care ♣ L547 Detailed statement of scope and frequency of services ♣ L548 Measureable outcomes anticipated ♣ L552 Review and revise POC at least every 15 days or more if patient’s condition warrants ♣ L553 Revised plan of care includes information from updated comprehensive assessment ♣ L554 Coordination of care ♣ L555 Ensure care/service in accordance with the plan of care ♣ L557 Sharing of information 418.76 Hospice Aide Assignments and Duties ♣ L625 Written hospice aide instructions ♣ L626 Hospice aide assignment and duties ♣ L629 Hospice aide supervisory visits END.

Thursday, March 14, 2019

The Cost of Alzheimer's Disease: Tips for Loved Ones

                                                                  Photo via Pixabay

Article written by Scott Sanders:

The Cost of Alzheimer's Disease: Tips for Loved Ones

Covering the costs associated with an Alzheimer’s disease diagnosis can quickly become overwhelming, even if there are savings or health insurance benefits. Treatment and medication can get costly very easily, leaving patients struggling to make ends meet when they should be focusing on their health. If your loved one was recently diagnosed with Alzheimer’s, it’s important to do research and find out all you can about the disease and the costs associated with it. Being well informed is half the battle and will help you stay on top of finances.

The key is to think not only about current needs but future ones as well. Your loved one may require long-term care, which can become very expensive over time -- even with health insurance or Medicare, which may not pay for everything. Thinking and planning ahead will help you and your loved one prepare for any issues that may arise without adding to your stress.

Keep reading for some great tips on how to cover the cost of Alzheimer’s disease.

Find the Right Insurance

There are many different types of insurance, and for those who have serious health issues, final expense insurance can be very beneficial. This can help prevent any problems with paying for your loved one’s final wishes or covering medical bills, which will take some of the pressure off of you or your loved one’s spouse.

Look for Assistance

If your loved one doesn’t have the savings to pay for their care, or if their health insurance won’t cover what they need, it may be time to look elsewhere for assistance. There are several programs that will help individuals pay for treatment and medication, and they all have different requirements, so it’s important to do some research and get informed on the necessary applications and forms. In most cases, your loved one’s doctor will need to fill out some paperwork, so try to be patient during this process.

Think Carefully About Your Role

Some individuals who have been diagnosed with Alzheimer’s disease hire a caregiver to help them with daily activities; others ask a close friend or family member to take on this role. Think carefully before committing to the job, as it’s extremely involved and will require a lot of time and physical effort. If you do decide to help out in some capacity, do some research on the best ways to help your loved one with daily activities and allow them to retain their dignity.

Get Familiar with What Medicare Covers

All health insurance plans are different, and Medicare is no exception. It can be confusing to figure out what your loved one’s policy will cover, so do some research and get familiar with what it will pay for. In general, Medicare will pay for inpatient hospital care and medical fees for patients over 65, as well as a limited amount of prescription drugs. It only pays for up to about 100 days of care in a nursing home, however, which is important to note.

The cost of Alzheimer’s disease will vary for each patient, but if you are well-informed and prepared, you and your loved one can plan for their current and future needs without stress. Don’t be afraid to ask for help when you need it, especially if you are feeling overwhelmed. A serious diagnosis like Alzheimer’s disease can leave the patient and their loved ones feeling depressed, anxious, and stressed, so it’s important not to neglect your needs.

Friday, October 19, 2018

How to Cope with the Death of a Loved One When You’re Miles Away

There are many reasons you might not be able to attend the funeral of a loved one, but perhaps the most difficult to accept is distance. Whether you can’t afford the trip or have obligations that prevent your attendance, grieving from afar is never easy. There are ways, however, to begin the process, even if you can’t be there to say goodbye.

Acknowledge Your Feelings

There is no way around sadness associated with loss. And though it’s tempting, don’t try to ignore your feelings by focusing on other things. You will not grieve faster nor will your anguish diminish by bottling your emotions. In fact, keeping your feelings at bay can actually make things worse for you long-term. Not giving yourself the chance to release your feelings will keep them buried just below the surface but always lingering over every moment.

Find a Positive Outlet

While you should not ignore your feelings, you should find a productive way to channel your emotions so that you may better cope with your loss. This is especially important when you aren’t in close enough proximity to help with funeral arrangements or to simply seek comfort with others who share your pain. Consider taking up painting or writing in a journal as a way to get you through those moments when all hope seems lost.

Learn to Manage Your Stress

Chances are, if you’re unable to attend a loved one’s funeral, you’re under a fair amount of stress and anxiety. If left unchecked, these emotions could lead to dangerous health problems, including high blood pressure. To help reduce stress, even if just a little, it’s important to look for techniques you can incorporate into your day. For example, you might decide to take up meditation or spend some time doing yoga. However, if you don’t have the time or energy for those activities, look into the benefits of stretching. Doing simple moves (lower back stretches, neck rolls, chin tucks, etc.) can release tension, improve your circulation, relax your muscles, and even boost your energy levels throughout the day.

Keep Up Communication

Fortunately, we live in a world where we can stay in contact with our loved ones 24/7 without ever having to step foot outside of our home. One of the most important things you can do for yourself and your family is staying in touch. This will help not only you through this trying time but will be of comfort to others. Video calls will allow you to have some valuable face time so that you can discuss your memories of and feelings related to the deceased. Apps such as Marco Polo will even let you send and receive video messages when real-time communication isn’t possible. These messages are even more valuable when you are in a remarkably different time zone than those with whom you need to remain in contact.

Prioritize Yourself

It might sound selfish, but you must learn to put yourself first throughout the grieving process. The American Cancer Society reports that grieving individuals often succumb to their intense emotions and withdraw socially, experience depression, and even feel guilty or blame themselves for the loss. You can prevent many negative behaviors by remembering that you still have your own life to live. Monitor yourself for behaviors such as isolation, drug, and alcohol use, poor hygiene, and preoccupation with death. Don’t be afraid to reach out for help if you find yourself getting lost in a bad place emotionally.

As hard as it is to accept, death is something that waits for no one. You cannot postpone the death of a loved one or bring them back so that you can be there for their passing. All you can do now is honor their memory and keep them close to your heart. Even a small memorial is a meaningful way to remember your loved one that can help you through the mourning process. No matter how you choose to mourn or how far away you may be, grief is a part of life and one that we must all inevitably experience. Stay in touch with your surviving loved ones and remember the dearly departed in your own special way. This will abate your misery and help you lead your own healthy and productive life.

Image via Pixabay

Tuesday, October 9, 2018


Planning Ahead for the Future: Tips for Seniors
Photo via Pixabay by Geralt
Thinking about your future needs can be tricky; no one can predict where they’ll be in five or 10 years. However, there are many things that can give you a good idea of what your health needs will be, and it’s important to consider this when you’re planning ahead. For many seniors, finding a way to pay for potential medical issues can be stressful; even those with health insurance and Medicare may need to pay for some things out-of-pocket, and those costs can really add up. Your post-retirement savings may not be enough to help you get through, especially if you need long-term care after an injury or illness.

One of the keys to planning for the future is to take a look at your current lifestyle and wellness. If you have health issues that could possibly be improved by diet or other lifestyle changes, it’s important to talk to your doctor and figure out the best way to get started. If you’re predisposed to certain diseases due to a family history, look for ways to stay as healthy as possible. 

Keep reading for the best tips on how to plan for your future.

Think About the Right Insurance

The right insurance will help you prepare for any issues that come along during your senior years, but it’s important to plan ahead. For instance, getting long-term care insurance when you’re younger can save you money; typicallyrates increase by 2 to 4 percent when you’re in your 50s compared to 6 to 8 percent in your 60s. This type of insurance can help you pay for your care should you need to stay in a nursing home or hospital for an extended period of time.

Take a Look at Your Current Health

For most seniors, a good diet and exercise plan can go a long way toward maintaining good health, but if you suffer from mobility issues, diabetes, or have a lifestyle-related issue such as a chronic cough from smoking, it’s time to take a look at how you can make some positive changes that will help boost your health for the future. Talk to your doctor about how you can get started, and remember not to make any big changes without prior approval. 

Pad Your Savings

Your savings account is a major factor in how you’ll find the funds to pay for medical bills and long-term care should you need it, and even if you have a good amount put back, it’s always a good idea to pad it a bit. You can sell a life insurance policy, downsize to a smaller home, or switch to energy-efficient appliances and lighting to save money on your utility bills each month. Look for the best ways you can save money while still focusing on your needs.

Make Your Current Home Work for You

Aging in place is important to many seniors, but it’s not always a viable option due to the layout of a home or potential safety hazards. In order to make sure you can stay in your own home for as long as possible without fear of injury, make some simple modifications that will keep you safe, such as adding a grab bar and non-slip mat in the shower, placing more lighting in each room to prevent falls, or adding a ramp to the front of your home. 

Planning for the future can be stressful, so it’s important to go slowly and garner support from your friends and family during the process. Talk to other seniors who have made changes to their homes and lifestyles to get some advice on how to proceed, and remember not to make a major decision until you have all the facts. With a good plan, you can ensure your future looks bright.

Wednesday, August 8, 2018

Financial Security During a Time of Terminal Cancer

Everything changes when you receive a terminal cancer diagnosis.  Along with an altered perspective, chances are you need to cover substantial treatment costs.  How do you manage so you and your loved ones can feel financially secure during this difficult time?

Establish security.  A terminal diagnosis is devastating to you and your family in many ways.  It’s important to create a financial safety net to cover the costs associated with treatment and to provide for family members after you’re gone.  In the midst of an overwhelming time, sorting out the details of money and bills can seem like a luxury, but by putting things in proper order you can face your situation with some peace of mind. 

Access cash.  Along with cancer and a terminal diagnosis, many people face the almost immediate loss of income.  Not only do you need time off for any treatments you’re receiving, your spouse is likely taking time to help.  MoneyTalksNews suggests tapping into any resources of cash outside of routine income.  Some insurance policies provide a living benefit option.  In other words, you might be able to receive a portion of a death benefit in advance. Also, some insurance policies offer supplemental benefits for those with terminal cancer.  For example, some Medicare Advantage plans can cover medications, dental work and other treatments related to your diagnosis. 

Photo Image courtesy of Pixabay

Other sources of cash.  Perhaps you own assets that are no longer practical, such as an extra vehicle or retirement fund.  Look around for items of particular value such as expensive tools, a camper or motorcycle.  Another idea is to take out a mortgage on your home.  If you are single, own your home outright and don’t have anyone you plan to pass your estate to, it’s an option worthy of consideration. 

Government assistance.  When you stop working, you can apply for Social Security disability funds.  People diagnosed with a terminal illness can receive expedited processing of their disability claim, however, they still will wait five months before receiving benefits.  That means you’ll need to find other means for filling in that gap.  Note that even if your diagnosis is for less than five months of survival, it still makes sense to apply, especially if you have a spouse or children. 

Lifestyle changes.  Depending on the nature of your diagnosis, Time explains it may make sense for you to downsize your home.  A more manageable home can be easier for you and loved ones to navigate, both physically and financially.  As treatment and care burdens change, living in a smaller, single-floor home can help with the upkeep of the house, easier movement coming and going and reduced utilities.

Networking and resources.  There are many viable personal networking options to help pay for cancer treatments.  Reach out to friends and family, your local community and online friends.  You can benefit from bake sales, silent auctions and yard sales.  Some experts suggest electronic outreach since thanks to the Internet and social media funds can be raised far and wide through websites such as  Also, note there are many resources available through national service organizations. 

Plan for later.  In the midst of your financial concerns, the future of loved ones can weigh on your mind.  You should establish a will and check the beneficiaries on your various accounts and insurance policies.  As Forbes points out, you also should consider the impact of your situation on income taxes.  Many times your final year means a drastic income reduction for your household, followed by a substantial increase the next year as benefits payout.  Consider consulting a tax advisor or other financial professional regarding the particulars of your situation.

Some of the trials involved with facing a terminal diagnosis are navigated more comfortably when you have secure economic footing.  Find funds to help pay for your treatments, adjust your lifestyle and reach out to potential resources.  Your journey can be eased with solid financial planning.