For both hospice and home health, CMS will continue to pay for the administering of COVID-19 vaccines and some antibodies. However, when it comes to telehealth services, hospice and home health differ in that only Face-to-Face encounters via telehealth are permitted for hospices once the Public Health Emergency is over. Effective May 12, 2023, routine home care visits for hospice will no longer be allowed via telehealth.
It is important to remember that all telehealth services that do take place must be done using a HIPAA-compliant telehealth system following the end of the Public Health Emergency. Non-HIPAA compliant forms of telehealth, such as Skype and Zoom, have been allowed by CMS for use during the PHE, but effective May 12, 2023 they will only be allowed via systems found to be HIPAA compliant. Click here for more information.
Hospice providers must ensure that all Face-to-Face encounters conducted via telehealth are accurately documented in the patient’s medical record. Such encounters must be audio and video enabled, and documentation must reflect this. The temporary allowance of telehealth for Face-to-Face encounters has been extended through December 31, 2024. Therefore, it is essential for hospice providers to maintain accurate records in compliance with current regulations.
Hospice providers face several changes with the end of the Public Health Emergency on May 11, 2023, including the end of two 1135 waivers granted regarding hospice aides. These waivers include the requirement for an annual on-site, in-person visit and the need to provide 12 hours of education for hospice aides annually. Without these waivers, Hospice providers will be obligated to comply these regulations again.
After the conclusion of the Public Health Emergency, the QAPI program must return to its full scope of requirements. This includes, in addition to the current focus on infection control, all other necessary elements be reinstated to your QAPI program to ensure the highest quality of care is provided.
After the expiration of the 1135 waivers on May 11, hospices will need to return to their pre-emergency requirements for volunteer services; specifically, they must ensure that at least 5% of patient care hours are made up of volunteer hours.
There is a fact sheet for the items ending or adjusted with the end of the Public Health Emergency which you can find by clicking here.
The National Association for Home Care and Hospice recently hosted a webinar to explain the changes that must be made by May 12, 2023, and it’s important to review this information carefully to ensure compliance with all relevant regulations. To stay informed and up-to-date, individuals should access the webinar for further clarification.
If there is anything HPS can do for you, don’t hesitate to let us know.
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