National Home Care & Hospice Month – Share Your Story with ACHC!

November is National Home Care & Hospice Month, and the National Hospice and Palliative Care Organization’s (NHPCO) theme for this year is “It’s about how you live!”

ACHC wants to hear how your agency lives out this motto! Help us raise awareness about home care and hospice services by sharing an example of how you help your patients achieve a better quality of life. Email us your story at ainfo@achc.org, comment on our Facebook page, or tag us on Twitter.

At the end of the month we will select one participating agency to win a $50 Starbucks gift card! We will also be featuring your stories on the ACHC Blog, social media, and in the ACHC Today e-newsletter.

If you are looking for ways to celebrate and raise awareness about home care and hospice services this month, check out the National Association for Home Care and Hospice (NAHC) list of Celebration Ideas.

In this season of thanksgiving, we want you to know how grateful we are for the high-quality care you bring to your patients. We are truly blessed to be your accreditation partner!

Now Available: ACHC Home Health Standards & Educational Resources – Revised Medicare CoPs

On January, 9, 2017, CMS finalized the first major revision to the Medicare Home Health Conditions of Participation (CoPs) in more than 20 years. The implementation date for these new CoPs is January 13, 2018 and the phase-in date for Performance Improvement Projects is July 13, 2018, with all other QAPI requirements effective January 13, 2018.

The revised ACHC Home Health Accreditation Standards, which incorporate the new CoPs, are now available to download on Customer Central. In accordance with the implementation date, ACHC will begin surveying against these new standards on January 13, 2018.

As always, agencies must adhere to the most stringent regulations. Requirements deleted from the CoPs may still be valid in your state, so check state licensure requirements, as applicable, prior to revising any current practice.

We know that with these revisions comes heightened anxiety and concern regarding the ability to demonstrate compliance. ACHC has developed tools and resources to help educate providers on the expectations for compliance with the new CoPs and ACHC Accreditation Standards:

Accreditation University

Customer Central

 

 

Are You in Compliance with Emergency Preparedness Requirements?

On September 8, 2016, the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. Healthcare providers and suppliers affected by this rule must comply with and implement all regulations by November 15, 2017.

These Emergency Preparedness regulations have been incorporated into the Home Health Conditions of Participation (CoPs) and the Hospice requirements are in the State Operations Manual, Appendix Z- Emergency Preparedness for All Providers and Certified Supplier Types, Interpretive Guidance. ACHC recently received approval from the Centers for Medicare & Medicaid Services (CMS) for the revised ACHC Accreditation Standards that incorporate the new Emergency Preparedness requirements. These new standards are available to download on Customer Central.

You can view the interpretive guidelines and valuable resources to assist with developing your agency’s Emergency Preparedness Plan online.

ACHC has developed several educational resources to help you prepare for compliance with Emergency Preparedness Conditions of Participation:

Customer Central

DYK Educational Emails

Accreditation University

1st Recipient of ACHC’s Distinction in Hazardous Drug Handling Cites Positive Experience

PCAB-accredited Pharmacy Specialties & Clinic of Sioux Falls, SD, achieved an additional recognition in September when it became the first to receive ACHC’s new Distinction in Hazardous Drug Handling (HDH).

The Distinction in HDH gives ACHC- and PCAB-accredited pharmacies a means to demonstrate compliance with criteria set forth in USP Chapter <800> Hazardous Drugs – Handling in Healthcare Settings. While not set to go into effect until 2019, many pharmacies are taking proactive steps to ensure preparedness with these guidelines aimed at protecting pharmacist and patient safety.

Below, PS&C President Cheri Kraemer talks about her pharmacy’s experience preparing for and undergoing the HDH survey, and offers advice for those who may be considering it.

ACHC: Why did you decide to make your facility USP <800> compliant?

Kraemer: I have always tried to protect my employees from chemicals they work with on a daily basis and I have had a powder room for making capsules and hormones since 2010 so I just decided to finish the entire process since the deadline was July 1, 2018*, and I wanted to be ready.  I would rather be first to act than last when dealing with employee safety. (*The implementation date has since been postponed until December 1, 2019.)

ACHC: What were some of your biggest challenges?

Kraemer: I decided to move the cleanroom, which required a remodel.  We had glass walls and ledges in our old cleanroom, so to make it more efficient for cleaning, we built out a new cleanroom with a hard top, epoxy painted walls, and concave floors.

ACHC: What surprises did you encounter?

Kraemer: The expense; it is always hard to know what things will cost.  So to prepare, I sold my retail pharmacy portion to a local retail chain in order to have money to remodel and do this all properly.  We are compounding only now.  We do less than 5% sterile but I feel ready to do more now that we have gone through all the inspections.  I know many compounding pharmacies are dropping sterile because of the expense to make the changes needed. I want patients in South Dakota and our surrounding states to have access to all areas of compounding.

ACHC: What was easier than you thought?

Kraemer: The hazardous area was quite easy for me because I had a room separated already for many years.  I just needed to vent the hoods outside and designate the area hazardous; separate chemicals; change gowning procedures; and rethink all the various workflow processes.  An example is that you need more equipment. We needed a second ointment mill to put in the hazardous room for topiramate pediatric suspensions made from commercial tablets.

ACHC: What pearls of wisdom might you share with a pharmacy in the beginning stages of preparation for USP <800>?

Kraemer: Consider the hoods you will purchase before the buildout.  We did not make the ceiling in our sterile hazardous room high enough.  It should have been 1 foot taller to accommodate the new BioView hood.  I could not have known that because I did not realize the hood I was getting to put in there was so tall. The hood should be raised up for comfort.

ACHC: How do you feel about ACHC’s approach to addressing USP <800>?

Kraemer: I thought it was very thorough.   Going in to USP <800> certification, the Distinction in Hazardous Drug Handling, I had questions about the extra waste we will create using so many more chemo items.  It was really nice to have Jon Pritchett with ACHC and Brenda Jensen with Compound Consultants to work with regarding some of these details.

ACHC: Do you feel that the Distinction in HDH standards adequately addressed the chapter?

Kraemer: Yes, I was very ready for the inspection after working through the requirements set forth by ACHC/PCAB.

ACHC: Where do you see the compounding industry going? Do you think that hazardous drug handling will continue to be a topic of conversation?

Kraemer: I am ready for HD handling across the board, sterile and non-sterile.  I feel that if I could do this, everyone can do this and should do it sooner rather than later.  It is about safety to your employees, which should be the most important thing to consider when compounding with bulk chemicals and handling other NIOSH list medications.  I feel the sooner this all gets in place, the better for everyone in our industry.

 

CMS Home Health Prospective Payment System Does Not Include HHGM

Yesterday, November 1, 2017, the Centers for Medicare and Medicaid Services (CMS) released the final rule for the CY2018 Home Health Prospective Payment System (HH PPS). In the final rule, CMS announces that it will not launch the Home Health Groupings Model (HHGM) in 2019.

The final rule states:

“We received many comments from the public that we would like to take into further consideration. While comments were generally supportive of the concept of revising the HH PPS case-mix methodology to better align payments with the cost of providing care, commentators included technical comments on various aspects of the proposed case-mix adjustment methodology under the HHGM and were most concerned about the proposed change in the unit of payment from 60 days to 30 days and such change being proposed for implementation in a non-budget neutral manner. Commentators also stated their desire for greater involvement in the development of the HHGM and the need for access to the necessary data in order to replicate and model the effects on their businesses.”

This is not the equivalent of withdrawing the proposal; however, it is a clear victory for the home health providers and advocates who spoke out against the rule.

CMS Releases Draft Version of the HHA CoP Interpretive Guidelines

Today the Centers for Medicare and Medicaid Services (CMS) released the draft version of the Home Health Agency Conditions of Participation (HHA CoP) Interpretive Guidelines to industry stakeholders. The National Association for Home Care and Hospice (NAHC) has made the guidelines available to its members for comment. CMS is unable to accept individual comments, but NAHC will be compiling feedback from its members and will present this feedback to CMS.

Managing Change: An Interview with Teresa Gregory, Corporate Director of Medical Services of America

The Remington Report interviewed Teresa Gregory, Corporate Director of Medical Services of America on behalf of Accreditation Commission for Health Care (ACHC). Medical Services of America is a comprehensive home healthcare provider that offers home healthcare provider that offers home healthcare, hospice care, home medical equipment and supplies, diabetic supplies, respiratory services, mail order supplies, home infusion therapy, enteral nutrition therapy, senior/assisted living, full service pharmacy, physician practice management, and billing and printing services.

 

Remington Report: As a leader, you’re required to play multiple roles within your teams and your organization as whole. How is your organization managing change?

Gregory: Medical Services of America has been caring for individuals in the community in one capacity or another for 43 years. Unfortunately, due to constant regulatory constraints and requirements, the past 3 years have by far been the most challenging. MSA has responded to change by operating as effectively and efficiently as possible, all while continuing to monitor and respond to the ever-changing reimbursement environment.

With any new regulatory/reimbursement initiative, MSA understands that it takes a team effort to build a business strategy that will enable our organization to be prepared with minimal disruption to our operations and patient care. We bring subject matter experts from many departments to the table so that we are able to understand all aspects of the impact that decisions made will have on everyone. As the leader in this process, this can be quite challenging at times, but very necessary for the positive outcomes we are looking for.

One of MSA’s strengths is in the support and involvement of its Board of Directors in managing the constant changes within the industry. The Board of Directors has been progressive in allowing the organization to make technology, clinical, and policy changes as needed in order to compete in this new environment.

Remington Report: How has ACHC’s partnership helped to manage change?

Gregory: ACHC has helped MSA manage change by becoming a tremendous resource and partner. As an organization, if we have questions as we consider changes, we feel very comfortable contacting ACHC to validate that our solutions are within the standards set forth by their organization.

Being accredited by ACHC also provides company’s leadership with reassurance that we are well positioned for future changes as they send out newsletters, workshop information, and emails to keep us up to date on upcoming issues and policy changes. Working with ACHC is very much a partnership in ensuring that we are providing the highest level of care to all patients in all geographic areas. We always value their input.

Are You Asking the Right Questions About the Cost of DME Accreditation?

“Many companies regret not doing more comparison shopping when choosing their accreditor. Sometimes the cheapest selection ends up costing more in terms of service, additional fees, or resource burdens for the provider,” says Tim Safley, ACHC’s Director of DMEPOS, Pharmacy, and Sleep.

Providers may think they are locked into their current accreditation organization, or that there is little difference among accreditors. “In fact, there is much to be gained by looking closely at how accreditation organizations stack up in terms of understanding an organization, their approach to the survey, the quality of their Surveyors, educational support, reputation within the industry, as well as price and pricing options,” Safley says.

Costs can vary significantly among accreditation organizations. In determining the complete cost of your three-year accreditation, make sure you understand how the AO structures fees by asking the right questions and demanding transparency.

      • Is the accreditation cost a flat rate or based on the size of your organization?
      • Is the accreditation cost a one-time charge at the beginning of the cycle or are there additional annual fees?
      • Are Surveyor travel expenses included?
      • What are the charges if a resurvey is required?
      • Is there a charge for standards initially?
      • Is there a charge when standards are updated?
      • Does the AO offer payment options to help better manage cash flow?

To avoid surprises, make sure all fees are disclosed and detailed in the agreement you establish and consult with your company’s legal counsel if you have concerns.

At ACHC, our pricing is all-inclusive, so you know exactly what you are paying for up front. This price covers your survey as well as all three years of your accreditation. In addition, payment options are available. While there is a $199 charge to obtain standards initially, a $100 discount is applied towards accreditation if your organization contracts with ACHC. There is never a charge when standards are updated. ACHC also allows for additional discounts on accreditation if you are a member of an ACHC partner organization, or attend an ACHC workshop. For further information, contact us at 855-937-2242.

The Role of the IDT in Meeting Hospice Regulatory Requirements

The essential function of the interdisciplinary team, IDT, is to work together as a cohesive unit to meet the physical, emotional, spiritual, and psychosocial needs of the patient and family. The expectation is all members work as equal partners in addressing the patient’s and family’s identified needs associated with the terminal illness and related conditions.

The IDT also has regulatory requirements that must be met in order for Medicare-certified hospice providers to participate in the Medicare program.

The federal regulations that pertain to the provision of hospice services are known as the Medicare Conditions of Participation, commonly referred to as the CoPs. So often the members of the IDT do not have a solid understanding of the CoPs and the impact their documentation or lack of documentation has on an agency’s ability to bill Medicare for services provided.

The delivery of hospice care is based on the comprehensive assessment and the individualized plan of care, both of which require the involvement of the IDT.

The comprehensive assessment is intended to assess the patient and family from a holistic point of view, not just from a medical perspective. The purpose is to “identify the physical, psychosocial, emotional, and spiritual needs related to the terminal illness that must be addressed in order to promote the hospice patient’s well-being, comfort, and dignity throughout the dying process” from which the IDT is to develop an individualized plan of care to address the identified needs.

Hospice providers are allowed to choose their own methods in which to complete the comprehensive assessment. Regardless of the process, all IDT members are expected to contribute. Often when a patient refuses a discipline, the documentation fails to support the continued input of the refused discipline. Regardless of the patient’s acceptance of the various members of the IDT, all members are expected to act as a resource to the other disciplines that are providing care to assist them in meeting any psychosocial, emotional, and spiritual needs of the patient and family.

Once the comprehensive assessment has been completed, an individualized plan of care must be developed that specifically addresses “the hospice care and services necessary to meet the patient- and family-specific needs identified in the comprehensive assessment as such needs relate to the terminal illness and related conditions.” There should be a direct link between the needs identified and the services ordered. Oftentimes a need is clearly identified, but the documentation does not demonstrate how that need was addressed. This tends to occur when a discipline is refused at admission and a team member documents an unresolved issue but does not document the follow-up to address that issue.

The plan of care must also be based on the identified “patient and family goals and interventions based on the problems identified in the initial, comprehensive and updated comprehensive assessments.” Documentation should clearly demonstrate the IDT is working toward the achievement of the patient- and family-identified goals. In circumstances where goals are not met, or new needs arise, documentation must reflect a revision to the plan of care in an attempt to address unresolved goals or newly identified problems.

In order to accomplish these vital functions of the IDT, documentation of the coordination of services is crucial. The expectation is “the hospice must develop and maintain a system of communication and integration, in accordance with the hospice’s own policies and procedures, to ensure that the interdisciplinary group maintains responsibility for directing, coordinating, and supervising the care and services provided.”

We have all heard, “if it’s not documented, it’s not done.” This remains true, as without documentation to show that all members of the IDT participated in the completion of the comprehensive assessment, the development of the plan of care, and the coordination of care, hospice providers risk being cited deficiencies during a survey. More importantly, they lack evidence that the best possible care was provided to the patient and family during the most difficult time of their lives.

ACHC Extends Well Wishes to Hurricane Victims

The thoughts and concerns of everyone at ACHC are with those in Texas dealing with the horrific aftermath of Hurricane Harvey.  As selfless healthcare workers continue to provide medical aid to patients – often at great risk to themselves – we are hopeful for the safety of providers and their patients.

We will keep those healthcare providers, their families and loved ones in our hearts. Our hope is for a rapid recovery and restoration to normalcy for those who have been impacted during this unprecedented tragedy.  ACHC-accredited providers are encouraged to contact their Account Advisor with any questions or issues.  ACHC encourages anyone who is so inclined to donate to a trusted charity or relief agency involved in helping hurricane victims in Texas.

The Centers for Medicare and Medicaid Service (CMS) has specific resources pertinent to Hurricane Harvey on its website here as well as here

When a natural disaster, extreme weather or emergency occurs that affects providers and the Medicare beneficiaries they serve, special emergency-related policies and procedures may be implemented. For detailed information on these policies and procedures, please see the CMS resources here and here.