On January 30, 2023, the White House stated that there will be an extension of the Public Health Emergency through May 11, and the Public Health Emergency will officially end on that day. Extending it to May 11 officially gave the 60-day notice that the White House had promised previously. So, we are here to discuss this today to ensure you understand the significance of some things you have been using in your daily practice of your organization that may cease on May 11.
TELEHEALTH COMPONENT IN HOME CARE AND HOSPICE
The 1135 waivers, put in place in March 2020, will now cease and you will not have access to those anymore. Telehealth has been a part of Home Health and Hospice for years. Not used as much as it was during 2020 and 2021, but the primary components were still available to be used. We had been approved, upon the beginning of the Public Health Emergency, to begin providing telehealth visits for face-to-face encounters via audio/video. Telehealth was originally put into the flexibilities a few months ago that face-to-face encounters would be allowed for an additional five months after the end of the Public Health Emergency. In the Omnibus Spending Bill passed at the end of 2022, they passed that telehealth could be used for Home Health and Hospice face-to-face encounters through December 2024, which you will still be able to conduct even though the Public Health Emergency will end in May 2023.
START OF CARE COMPREHENSIVE ASSESSMENT
Another key factor is the Home Health situation, with therapists allowed to start care. Under the 1135 waivers, if there is an order for skilled nursing and therapy, therapists can conduct the Start of Care Comprehensive Assessment instead of a nurse. As of the end of the Public Health Emergency, that will no longer be the case. Once we reach May 11, if it does officially end as they have stated, you will no longer be allowed to have a therapist do a Start of Care Comprehensive Assessment of a Home Health patient if nursing has been ordered. It will default to the current OASIS requirements.
COVID-19 VACCINATION REIMBURSEMENT AND FLEXIBILITIES FOR HOME HEALTH AND HOSPICE
In addition to that, they do intend to continue to reimburse both Home Health and Hospice for COVID-19 vaccinations to your patients.
Be careful because with the flexibilities for Home Health and Hospice, they may not have included the language for the face-to-face encounter to be extended via telehealth through December 2024 yet. All the other flexibilities will apply with the end of the Public Health Emergency.
Please begin planning now for any of these waivers to end, including multiple ones regarding Home Health Aide Supervision as all of those are going to end on May 11 and you will go back to the original requirements for Home Health Aide Supervision, annual training, and so on.
If you need any assistance as you prepare for the end of this Public Health Emergency, please don’t hesitate to let us know.
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