Category: Medicare Regulations

When it comes to reducing patient readmission rates and avoiding financial penalties, infections can be a home health agency's worst nightmare.

Improving infection control protocols to comply with CoPs changes

When it comes to reducing patient readmission rates and avoiding financial penalties, infections can be a home health agency's worst nightmare. One particularly dangerous type of infection, sepsis, has grown more prevalent in recent years and often leads to rehospitalization. 

What HHAs need today are robust infection control policies and procedures. While some agencies were previously not required to implement such programs, the new Medicare conditions of participation (CoPs) have made it mandatory that all HHAs have a comprehensive infection control protocol. 

Let's take a closer look at what this new mandate means for your organization:

Understanding infections in the home health – hospital relationship
Researchers from the Columbia University School of Nursing conducted a study of 199,462 patients at 8,255 home health care agencies. They found that 3.5 percent of patients developed infections during their stay, and that 17 percent of unplanned hospitalizations were due to infections.

The study was published in the American Journal of Infection Control in 2016. While it found a relatively small incidence of infections in HHAs, there has been a notable surge in sepsis in hospitals. As a referral partner, this increase presents a greater need for sepsis monitoring and vigilance in home health agencies. 

health Evidence-based protocols can improve infection control at home health agencies.

The rise of sepsis in hospitals
The number of sepsis cases in the U.S. has been rapidly rising in recent years. Between 2005 and 2014, the incidence of hospital stays due to sepsis nearly tripled, according to a report by the Healthcare Cost and Utilization Project published in June of last year. Sepsis is now the No. 1 reason for hospital stays, according to new data from the Agency for Healthcare Research and Quality, Bloomberg reported. 

To deal with the rise of sepsis, New York State now requires all health care agencies to implement new evidence-based screening and treatment protocols. As a result of the new processes, sepsis mortality has decreased nearly 16 percent in the past two years. Other states have followed suit, with Illinois, Wisconsin and Ohio implementing infection protocols modeled after the New York program. 

Thornberry Ltd. also updated its NDoc® solution to better address sepsis, adding additional patient screening questions and expanding the Signs and Symptoms table to capture more detailed information relating to the condition. With these tools, providers can institute more effective evidence-based treatment protocols. 

Changes to the Medicare CoPs
Infection control has always been a part of HHAs' provisions of care, as mandated by their state's requirements. Those that were accredited by the Joint Commission or CHAP already had to have infection control policies and procedures in place. However, CoPs changes have now made it mandatory that all HHAs have an infection control program. Read the release on the final rule here

"CoPs changes have now made it mandatory that all HHAs have an infection control program."

Enhanced infection protocols in EMRs
The sepsis protocols highlight a need for HHAs across the country to have more robust infection control programs in place. Many EMRs only give nurses the option to document Yes/No as to whether the patient exhibited signs of an infection, and reports simply gave the the option to show if the patient had a catheter and if they were on an antibiotic.There was no report to calculate the number and type of infection. 

However, Thornberry Ltd. has introduced enhanced infection control protocols. In NDoc®, clinicians can now fill out a new section that captures more information about current and potential infections and easily coordinate additional lab work and cultures. Then, they can run a report for the number and types of infections for all of the agency's patients to quickly get a better idea of infection risk and trends and determine whether the infection was likely agency-acquired. 

These new processes give a more detailed picture of what an agency has done to prevent and treat infection. This information can then be used for performance improvement initiatives and staff training. 

The number of documented sepsis cases has been increasing, but with improved infection control protocols now mandated for use by all providers by the new CoPs, HHA are better equipped to identify, treat and ultimately prevent infection. 

It's not pleasant to think about, but you need to have a plan in place for dealing with emergencies at your agency.

Complying with the new CoPs rule on emergency preparedness

Disaster striking your home health agency is not a pleasant scenario to imagine, but one that's necessary to think about. It's essential to have an emergency plan in place ahead of time so that you can quickly pivot operations and continue providing care to patients. 

Being prepared for a disaster is all the more relevant in the HHA industry at the moment because emergency preparedness is now a part of the Medicare conditions of participation (CoPs). HHAs are now required to have an emergency program. 

Here's what you need to know about developing emergency preparedness at your agency:

Understanding the CMS rule 
The Centers for Medicare & Medicaid Services now mandates that all agencies must have an emergency preparedness plan. Such a program should protect patient health in the event of an emergency that affects operations, and covers both natural and man-made events, according to CMS. 

CMS says the emergency plan should be based on four main areas:

  1. Risk assessment and emergency planning. 
  2. Policies and procedures. 
  3. Communication plan. 
  4. Training and testing. 

CMS requires that continuous testing of the plan is performed to see if it needs updating or changes from lessons learned. Read more about the rule here

Creating your plan 
Keeping these four guidelines in mind, your emergency plan should specify what steps to take in the event of a disaster. Think about potential scenarios, such as what should be done if there is a water main break, gas leak or shut off, blackout, fire or loss of power. How will you communicate with patients if a phone system is down? Are there steps you can take to prepare for an impending natural disaster, such as a hurricane or wildfire? What actions should be taken in the event of man-made event, such as a robbery or active shooter? How will the authorities be contacted? These and other questions need to be extensively explored. 

"Key to effective disaster preparedness is having constantly up-to-date information on patient needs."

Establishing a priority list 
Another important issue is determining how you will prioritize patient care in an emergency. How will you manage those patients whose care relies on electricity and water?

An EMR with disaster preparedness features will provide essential triage support. Using Thornberry's NDoc® solution, nurses can run a Priority List report which tells them which patients on oxygen need to be seen, those who can be called and those with support who do not need to be called or visited during that time. 

Having the information you need ready 
The key to effective disaster preparedness is having constantly up-to-date information on patient needs. In NDoc®, nurses can add to a patient's emergency plan at any time to specify what may be needed for the individual's care in a disaster. For example, the nurse can note that the patient needs bottled water, batteries, matches, flashlights, enough medications for two weeks and so on. This data then pulls to a report that can be instantly retrieved in an emergency. Reports can be run daily and weekly so staff and clinicians have the most updated information on patients. 

With an in-depth plan and an EMR enabling up-to-date patient priority reports, your home health agency can comply with the CoPs and be better prepared in the event of an emergency. 

Big changes are afoot in the home health industry.

Understanding the new Medicare conditions of participation

Big changes are afoot in the home health industry. For the first time since the 1980s, the Centers for Medicare & Medicaid Services has finalized new conditions of participation (CoPs) for home health agencies to participate in the Medicare program. If you haven't yet, read the rule in its entirety

The changes go into effect on Jan. 13, 2018, and CMS just released a draft of its interpretive guidelines on Oct. 27. That means HHAs need to do everything they can in November and December to familiarize themselves with the new rules – and the draft guidance – and prepare for January compliance.  

Background on revisions 
 In 1997, CMS proposed a rule that included landmark revisions to CoPs for HHAs. However, due to public pushback and major developments in the home health industry, CMS ultimately dropped the CoPs changes and kept the second half of the rule, which was the Outcome and Assessment Information Set (OASIS). 

Yet CMS held onto the idea that it could still update the CoPs as it had intended to six years prior. However, in 2004 the U.S. Federal Register interpreted a related act as actually "rendering ineffective any proposed Medicare regulations that had been outstanding for three years or more." As a result, CMS scrapped the 1997 proposal and set to work developing an entirely new CoPs rule, resulting in a proposal released in 2014 that was finalized this year. 

Understanding the changes 
The ultimate goal of the new CoPs is to improve patient care

"[The rule] … reflects current best practices for in-home care, based on recommendations from stakeholders and medical evidence," said CMS Chief Medical Officer Kate Goodrich. 

"The new rule emphasizes enhanced customization of patient care."

The new CoPs focus on three main areas: 

  1. Patient-centered care. 
  2. Data-drive collaboration. 
  3. Outcome-oriented processes. 

Patient-centered care: The new rule emphasizes enhanced customization of patient care through the creation of an individualized Plan of Care (PoC) based on a more patient-centered assessment. The patient-oriented goal is further reinforced with the conditions requiring HHAs to share clear and comprehensive documentation with patients concerning their rights, as well as written information about the details of their care.

Data-driven collaboration: The CoP rule demands greater care coordination efforts and expanded interdisciplinary communication to ensure all providers involved in patient care are focused on the patient's needs. This targeted approach places an even higher priority on interoperability of patient data between HHAs and other providers. Detailed PoCs need to be readable, shareable and accessible by all stakeholders.

Outcome-oriented processes: The new rule also emphasizes progress toward patient care goals. This is seen in its radically new Quality Assurance Performance Improvement CoP, which tracks HHAs' progress toward achieving specific outcomes. As part of QAPI, HHAs will have to undertake Performance Improvement Projects at least annually that measure progress in identified problem areas. 

Preparing for change 
If you feel that the new Medicare CoPs are overwhelming, you're not alone. But by learning as much as you can about the rule and its guidance now, and taking steps to prepare your agency to implement the changes, you can experience a smoother transition come January. 

The best defense is documentation.

Agencies rely on documentation as audit fears spike

The buzz in the home health and hospice industry is that government audits are ramping up. The Centers for Medicare & Medicaid Services are sending out more Zone Program Integrity Contractors and Recovery Audit Contractors to look for evidence of noncompliance. ZPIC audits are especially worrisome – "the most feared type of Medicare auditor" – as they are tasked with investigating suspected fraud and are able to pursue civil or criminal prosecution against suspected agencies, as Home Health Care News explained.

Innocents could stand accused
In some cases, small mistakes in documentation can cause otherwise innocent agencies to be implicated in fraud. MedPro Health Providers, a home health agency in Chicago that was recently named the best small workplace by the Chicago Tribune, is dealing with one such nightmare right now, according to HHCN. A ZPIC audited the agency and then alleged it had made improper payments, in response halting its Medicare reimbursements. MedPro's owner is suing the contractor for failing to properly review the extensive documents it sent that rebutted the allegations.

"The consequences of even honest mistakes can be dire."

However, damage has already been done, with hundreds of patients discharged and staff let go. MedPro's lawyer estimates that 40 other agencies also may have suffered "unfair audit practices" by ZPICs. Those agencies may join the lawsuit. 

"[With an audit], you feel a little scare or threatened," said the owner of MedPro, Rizaldy Villasenor, in an interview with HHCN. "Right now, it's anger that I am feeling …. The worst thing is letting the team go because of this. If I'm going to close the company, I say it won't be this way."

Stay vigilant
When it comes to defending against audits and fraud allegations, documentation is key. Villasenor was able to send detailed records and materials supporting his claim that MedPro is in the clear, and the ZPIC's alleged failure to follow correct due process when reviewing his rebuttal statements has enabled Villasenor to fight back with a lawsuit.

 Agencies should use interoperable EMRs that support comprehensive documentation of all care activities, from reporting to follow-up. This way, the risk of important information falling through the cracks is reduced. Agencies ensure they have all their activities thoroughly documented and detailed, so that in the event of a ZPIC or RAC audit, they have the relevant information ready as proof of compliance. 

As they say, the best defense is a good offense – and in the homecare segment, this means having ample and robust documentation protocols in place well before even the first sniff of an audit. Thornberry's NDoc solution was designed to ensure regulatory compliance and defend against accusations of fraud. Contact the team today to learn how NDoc can help your agency protect itself and its patients. 

Unnecessary or frequent readmission can negatively affect patient outcomes and can also impact a provider's ratings and reimbursements.

Strategies for preventing rehospitalization

The rate of patient rehospitalization is an important metric for home health care agencies to monitor. Unnecessary or frequent readmission can negatively affect patient outcomes and can also impact a provider's ratings and reimbursements. 

Home health agencies should do everything they can to prevent rehospitalization. Here are two effective strategies:

Use interoperable records systems 
One big reason that patients end up unnecessarily in the hospital again and again is that all the providers involved are using EMRs that are not interoperable, rendering any data that is exchanged unreadable or full of holes. Without a clear, connected system, patients can be discharged only to be called back due to gaps in records. Another scenario is that hospital clinicians fail to receive up-to-date and accurate information about a patients' medications, and then prescribe a drug that causes a negative interaction.

Through the interoperable exchange of health information, providers across the network can make sure they are on the same page for care plans, thereby reducing rehospitalization. In fact, a study published in the Journal of the American Medical Informatics Association revealed that the improved access to clinical data enabled by health information exchange systems reduced the chance of readmission by 57 percent

hospital The effective exchange of patient information can help reduce rehospitalization rates.

Improve follow-up 
Transitions of care are sensitive times prone to error, and keeping track of patient progress after discharge can also be fraught with difficulties. To prevent rehospitalization, it's important that providers have the systems in place to conduct thorough and timely follow-ups. EMRs that feature alerts, analytics functions and intuitive workflows can help staff and clinicians ensure they follow up with patients soon after they are discharged and that they can continue follow-up care on a regular schedule going forward. Providers should also effectively communicate care recommendations to patients, and this information can be more convenient to access if it is stored in a patient portal. With the clear exchange of information, all providers can be on the same page about which tests a patient has completed and what their care strategy is going forward. 

Analytics has great use in preventing rehospitalization. Through advanced data aggregation and reporting functions, EMRs can identify trends and outliers in patient health and provider visits. Analytics can isolate if there are certain patient groups that are particularly at-risk for repeated readmission. The feature can also help home health agencies gain a more detailed understanding of their rehospitalization record and the steps they can take to improve it.

Thornberry's industry-leading NDoc software features interoperability and analytics functions to help home health agencies reduce rehospitalization rates – contact us to learn more about our solution

The scoop on value-based purchasing: Part one [Video]

Value-based purchasing – it’s here, and it’s going to change home care across the country. 

The Centers for Medicare and Medicaid Services introduced a new value-based purchasing – or VBP -model this year that shifts how home health agencies are reimbursed.

The new model prioritizes quality of care as opposed to the traditional “fee-for-service” set up – in essence, the better care an agency provides, the higher the compensation they receive. 

The model measures quality of care by evaluating 24 measures, which include everything from communication between agencies and patients to vaccine coverage and improvements in medication administration to pain management. 

Only agencies in nine states – Arizona, Iowa, Nebraska, Florida, Maryland, North Carolina, Massachusetts, Washington and Tennessee – are subject to the new model as part of a pilot program, but it’s sure to extend to the rest of the U.S. soon. In part 2 of this series, we’ll share tips for preparing your agency to comply with VBP. 

The scoop on value-based purchasing: Part two [Video]

As you just learned, value-based purchasing, or VBP, is set to significantly change the way home health agencies are reimbursed. 

The new model rolled out by the Centers for Medicare & Medicaid Services prioritizes quality of care, and provide greater compensation to those agencies who demonstrate the highest levels of care and strongest patient outcomes. 

To successfully make the shift to the VPB model, home health agencies need to employ the most advanced and comprehensive EMR systems on the market.

EMRs that can collect and present a thorough and detailed portrait of patient health along with streamlined processes for data intake, analysis and exchange will help home health agencies provide the highest quality care possible. 

This new phase of home health requires a shift to a cutting-edge EMR. Don’t wait any longer – contact Thornberry today to see how their industry-leading NDoc solution can enable your agency to successfully transition to VBP and see the best patient outcomes possible.