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.
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.
“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 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.
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.
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.
Accreditation Commission for Health Care (ACHC) is thrilled to have been named one of the Best Places to Work in the Triangle by the Triangle Business Journal.
“Employees are the lifeblood of any company,” said TBJ Publisher Jason Christie in announcing this year’s pool of 50 honorees, which included a mix of familiar names and newcomers – one of which was ACHC.
“These 50 companies have demonstrated belief that happy employees produce successful and thriving businesses,” Christie continued. The winners are featured alphabetically in this slideshow and will be recognized at an awards luncheon on Sept. 22. TBJ will also publish a special section on the winners in its weekly edition.
“It’s our people who make ACHC the great company that it is, and we choose to invest in them accordingly,” said ACHC President and CEO José Domingos. “From flexible scheduling to wellness initiatives to an open-door management policy, we keep employee satisfaction at top of mind. With so many growing and thriving workplace options in the Triangle area, it’s wonderful to know that ACHC is regarded as among the best.”
With headquarters in Cary, NC, ACHC is located in Central North Carolina’s Triangle Region anchored by Raleigh, Durham and Chapel Hill. The area is home to multiple colleges and universities as well as the famed Research Triangle Park, one of the largest technology and research parks in the world.
This regional recognition comes on the heels of some national notoriety. Modern Healthcare recently named ACHC one of the Best Places to Work in Healthcare, while The Silicon Review included ACHC on its 2017 list of the 10 Fastest Growing Healthcare Companies.
At ACHC, our Surveyors are truly experts in their fields. Accreditation Corporate Surveyor Randy Hughes is no exception. Hughes is a registered Respiratory Therapist with over 45 years of experience whose areas of expertise include quality management, operational efficiency and medical gas CGMP compliance. Hughes recently wrote an article for HomeCare Magazine that examined accreditation considerations for alternative delivery models in HME. Read a condensed version below, or click here to read the full article. Congratulations, Randy!
Changing reimbursement environments, tightening regulatory requirements and managed care are forcing HME providers to develop alternative delivery models for equipment and services. The goal of each has been to provide service more efficiently and effectively while decreasing labor costs.
An important consideration with each model is “who owns the patient?” Who is responsible for providing products to the patient in the appropriate manner? This usually is driven by who bills (and who gets reimbursed) for the equipment or services provided. The “owner” needs to ensure that goods and services are delivered in a manner that meets all accreditation requirements.
The following are examples of alternative delivery models currently in use as well as the associated accreditation implications.
- Not new, but the types of products being shipped have evolved. Oxygen concentrators and CPAP therapy equipment are routinely sent through the mail, so much so that equipment manufacturers have become providers.
- Accreditation considerations:
- Documentation of shipping and receipt; patient education; evaluation of safety-related issues and the provision of care process; patient acknowledgement of receipt of patient rights and responsibilities; HIPAA acknowledgement; AOB, etc.
Group patient teaching
- New patient “classes” that include group demonstrations, patient education, and interface fitting.
- Gaining popularity for new and re-instruction CPAP patients and group compressor/nebulizer instructions.
- Significant increase in staff productivity; patient interactions have resulted in the formation of patient-hosted support teams.
- Accreditation considerations:
- HIPAA implications and patient confidentiality
- Adherence to infection control protocol and practices
- Assurance that each patient’s documentation is completed thoroughly and accurately and individualizing each patient as patient-specific issues are identified
- The billing entity provides the equipment and supplies while the subcontractor delivers the products. The most common model delivers re-supply items to patients, including reusable and disposable supplies and oxygen cylinders, where new patient teaching and instruction are not required.
- Accreditation considerations:
- Well-defined description of expectations from the subcontractor
- Clear description of the services to be provided, documentation requirements, delivery staff training, orientation and competency and others
- Written contract detaining the individual responsibilities of each party is required
- A performance indicator that monitors the services provided by the contracted organization
Nontraditional oxygen model
- The goal is to eliminate or minimize resupply visits to a patient’s home after the initial delivery of an oxygen deliver device, usually an oxygen concentrator.
- The most prevalent examples of this model are the various home oxygen cylinder filling units and the use of portable oxygen concentrators (POCs).
- Advances in portable technology are resulting in reliable, 3 to 4 LPM continuous flow capability, improved battery life, and continuous-use capability.
- Accreditation considerations:
- As long as the equipment is utilized and maintained as required by the manufacturer(s), the same accreditation standards that apply to a traditional oxygen concentrator apply to POCs
Non-clinical ventilator services
- Today’s ventilators incorporate sophisticated technology to provide multiple modes of ventilation, humidification, and alarm systems in one compact unit. Additionally, the explosion of non-invasive ventilation as an adjunct to or in place of invasive ventilation raises questions as to the need for these patients to receive Clinical Respiratory Services (CRS).
- Accreditation considerations:
- Providers who offer ventilator services as non-clinical are considered to be accredited for Equipment Management
- CRS is not required if the patient does not require ongoing assessment of the patients clinical status via a home clinical assessment ordered by the physician and performed by a licensed clinician
Impact of Technology
- Significant decline in cost.
- Will soon see an affordable device that is a POC and oximeter in one.
- Will include a modem similar to today’s CPAP units that will not only transmit compliance data, it will be an active interface that will facilitate remote troubleshooting, repair, and maintenance
- Many new questions will be posed from an accreditation perspective.
- What kind of doctor’s order will be required?
- What equipment maintenance and documentation is needed?
- What competency is required for a warehouse employee/delivery driver that remotely accesses a patient’s concentrator for troubleshooting?
- Is an RT required to teach the patient to self-titrate?
As we move through this continuum, many new questions will be posed from an accreditation perspective. Proactive communication with your Accreditation Organization about what models you are exploring and what impact they have from a standards interpretation perspective will help facilitate this transition.
For more information on ACHC’s accreditation programs or to download ACHC accreditation standards, visit http://www.achc.org, email email@example.com or call 855-937-2242.
Here at ACHC, we like to think that our success speaks for itself. Sometimes, though, it’s nice to know others are speaking about it.
ACHC recently received two honors that illuminate our good work and continued growth. Modern Healthcare named ACHC among The Best Places to Work in Healthcare, while The Silicon Review listed ACHC among the 10 Fastest Growing Healthcare Companies.
The Silicon Review asked ACHC CEO José Domingos to cite his company’s greatest assets. At the top of the list, Domingos said, are its people.
“As a service organization, our staff and the service they provide to our customers is what determines our success.” Next, he said, is an aligned purpose. Rounding out the list are flexibility, trust, and swift decision-making. Read the article here.
Modern Healthcare’s recognition program, in its 10th year, honors 150 workplaces throughout the healthcare industry that empower employees to provide patients and customers with the best possible care, products, and services.
Modern Healthcare will publish its annual Best Places to Work in Healthcare supplement on Oct. 2, 2017.
“We are both humbled and honored by these superlatives,” said CEO José Domingos. “ACHC has enjoyed immense growth during the past five years, and we anticipate much more as we expand our programs and services. Through it all, we remain committed to providing the best possible service to our customers – and to being an enjoyable and fulfilling workplace for our employees.”
June 16, 2017. The Pharmacy Podcast (www.pharmacypodcast.com), the nation’s most popular and downloaded podcast on the pharmacy industry, today featured an informational segment about the upcoming PCAB Sterile and Non-Sterile Compounding / USP Compliance workshop to be held July 25-26, 2017 at Fairleigh Dickinson University School of Pharmacy in Florham Park, New Jersey.
This podcast, featuring Pharmacy Podcast founder, Todd Eury, and FDU School of Pharmacy Dean, Michael Avaltroni, can be heard here: //html5-player.libsyn.com/embed/episode/id/5454258/height/360/width/640/theme/standard/autonext/no/thumbnail/yes/autoplay/no/preload/no/no_addthis/no/direction/backward/
The PCAB Sterile and Non-Sterile Compounding Pharmacy workshop provides pharmacy personnel with a comprehensive overview of the accreditation process and a standard-by-standard review of the requirements for sterile and non-sterile compounding. The two-day course is conducted with a personalized approach that delivers valuable insight into the accreditation process.
Since the highly-anticipated release of USP there has been much discussion among pharmacies about the interpretation of these new guidelines—and what that will mean for their operations once implementation takes full effect in 2018. During this workshop participants will examine the new standards and discover practical applications.
This workshop event, priced at $599 for the two-day session–or $499 for the USP segment only–will offer 8.75 ACPE-certified CEs (6.5 CEs for the USP segment only).
To register for the workshops:
PCAB Sterile and Non-Sterile/USP Compliance (2 day, Combined) http://www.accreditationuniversity.com/compounding-pharmacy-workshop.html
USP Compliance (1 day) http://www.accreditationuniversity.com/usp-800-compliance.html
This spring, Mountain Valley Hospice & Palliative Care became the first provider to achieve Accreditation Commission for Health Care’s newly launched Distinction in Palliative Care. For Denise Watson, MVHPC executive director, distinction has made a world of difference.
MVHPC, which has been ACHC-accredited for hospice since 2007, began providing palliative care services about five years ago. In late 2015, ACHC invited MVHPC to join a team – facilitated by Judi Lund Person of the National Hospice and Palliative Care Organization – that helped to develop ACHC’s Palliative Care Standards based on the National Consensus Project’s Clinical Practice Guidelines for Quality Palliative Care. In early 2017, MVHPC served as ACHC’s beta test site for those standards, undergoing a survey and ultimately earning the distinction. It was an experience that Watson says helped to make MVHPC’s palliative care program stronger and more structured, and that put the organization “a step above.”
ACHC followed up with Watson to learn more about MVHPC’s experience.
ACHC: Talk about your experience incorporating the ACHC standards into your practice.
DENISE WATSON: I put a team together with some of our top leadership and our medical director and our practitioners, and we started reviewing our (palliative care) policies and comparing what was lacking and where we did not meet the standards. We found we had a lot of work to do. So we went standard by standard to make sure that we had a policy. And we of course had to educate the practitioners and everybody that was a part of the program on what they had to do, because it was additional work, additional assessments. So it was a transition of changing a lot of the way we were doing things.
ACHC: What was an area in which you found your agency needed work?
DW: We didn’t really have any formal policies related to the interdisciplinary team. We were meeting once a month, roughly. We had to change the time and make it regular and really focus on that team care as opposed to just “here’s a referral; the nurse practitioner needs to see them.” So there was more structure and they had to follow certain policies and standards and processes that we were really very vague before.
ACHC: How did ACHC work with you to amend the standards based on your feedback?
DW: I really appreciate the fact that ACHC was open to listening to how the standards worked for us, per se, by changing policies and our processes. It was nice to know that we were part of making sure that we didn’t have overkill on the standards or maybe we didn’t have them strong enough. There was some movement there and flexibility that we could all come to an agreement, especially around the comprehensive assessment. Sometimes there’s a “one and done visit” and you never see (the patient) again, so we had to take that into account. Palliative Care, it’s different from hospice.
For example, with hospice there’s a comprehensive assessment for the nurse, chaplain, social worker. The issue is when our practitioners go out there to do the (palliative care) assessment, they have to ask questions about psychosocial; it’s all embedded in all these comprehensive assessments. What we elected to do is to have them ask a couple of simple questions. If they identify from those questions a need for spiritual or psychosocial assistance, then they make the referral to that discipline to do all those questions. What we were trying to do was limit the amount of detailed information a nurse practitioner or a physician had to get.
ACHC: Can you comment further on how does palliative differs from hospice?
DW: In Palliative Care, you’re focusing on a symptom, e.g. pain management. In hospice you’re focusing on all kinds of symptoms.
Hospice is much more intensive. You’re really supporting the entire family. We’ve tried to bring that into palliative care, but these patients are mobile. You may not have the family at the bedside. 60-70 percent of our patients in palliative care end up coming to hospice. You bring that interdisciplinary piece to it, but it’s not as involved. You’re focusing on that symptom, and you may find other stuff when you get in there, e.g. they need emotional support.
ACHC: How has MVHPC most benefitted from having achieved the Distinction in Palliative Care?
DW: We had tried, the entire time we were doing palliative care, to make our program structured. But we were lacking in structure and lacking in everybody knowing what they really should capture in a visit and then how they bring this back and share what they’re doing as a team, and then really talk as a team about goals of care.
It was fragmented, in my opinion, and this really brought structure to our program. And it made us do stuff that we had wanted to do, or had intended to do, forever. Our policies were very vague. It forced us to really put structure and meat to the program.
“I feel like our program is just much more structured. Everybody’s on the same page. It has been beneficial for us, for sure.”
ACHC: What does acheiving the ACHC Distinction in Palliative Care mean to you?
DW: It means we have taken the extra step to ensure our program provides quality service. We are taking steps that we didn’t have to do to improve our program. I think it says that we are doing this for the right reasons. The ultimate goal is to provide the best care to these patients. It’s a sense that somebody’s looking over our shoulder. Somebody’s looked at our program. Somebody has said, “You’re doing what you’re supposed to be doing.” It sets us a step above.
Mountain Valley Hospice & Palliative Care provides hospice services to terminally ill patients and their families in 17 counties from eight locations in North Carolina and Southern Virginia. Denise Watson has served as executive director since 1999, and has worked for MVHPC since 1994.