Call for Medicaid Access Rule Workgroup Participants

The National Association for Home Care & Hospice (NAHC) is forming a workgroup of NAHC members to help formulate our response to the recently issued Medicaid Access notice of proposed rulemaking.

Please indicate interest in participating by emailing NAHC’s Director of Medicaid HCBS at [email protected].

Click Here to learn more about the Medicaid Access proposed rule and the associated Medicaid Managed Care rule. 

Download NAHC Overview Slides

As Pandemic Ends, Other Home Care Challenges Await

McKnight’s Home Care | By Liz Berger
 
No sooner does one problem end than another one begins. That’s the theme this week from McKnight’s Home Care.

The big story Thursday, of course, was the end of the COVID-19 public health emergency. May 11 essentially sounded the death knell for the pandemic (not the novel coronavirus, sadly). Such uplifting news. After more than three years of fretting and masking and quarantining and isolating, we can actually start to think of life as it used to be — with caveats, of course. (Thanks to the dreaded virus, life may never be the same, but it’s certainly better and more relaxed than it has been these last three years.)

But just when you thought you were home free, you scroll down the page and other concerns start to creep in again. The second piece of content Thursday — a podcast — is about an impending Medicare home health proposed health rule. Geez. Do you have to bring that up again? you ask. We just got over the last one.

It sure seems that way, but it’s May, which means we are mere weeks away from possibly more bad news on the Medicare home health payment front. William Dombi of the National Association for Home Care & Hospice and Joanne Cunningham of the Partnership for Quality Home Healthcare are cautiously optimistic the Centers for Medicare & Medicaid Services will not slap the second half of the temporary behavioral adjustments on facilities. But we will have to wait and see.

And then, of course, there is a fresh worry on providers’ minds: a proposed mandate for Medicaid home care worker compensation. Specifically, CMS is considering requiring that 80% of Medicaid payments go toward home health, homemaker and personal care wages. Yikes is NAHC’s response, echoing other reactions from the field.

So here we are: one tough issue — the pandemic — dispensed with and two others on the doorstep. Never a dull moment, as they say. I suppose the silver lining is we can meet others without masks to talk about these events.

DEA Extends Telehealth Flexibilities for Six Months

NHPCO

The Drug Enforcement Agency (DEA) has extended “the COVID-19 telemedicine prescribing flexibilities for six months, from May 12, 2023 through November 11, 2023.” The following requirements must be met for the flexibilities to continue:

1. The prescription must be issued for a legitimate medical purpose by a practitioner acting in the usual course of professional practice.
2. The prescription must be issued pursuant to a communication between a practitioner and a patient using an interactive telecommunications system…[e.g.,] audio and video equipment permitting two-way, real-time, interactive communication.
3. The practitioner must be authorized under their registration…to prescribe the basic class of controlled medications specified on the prescription or exempt from obtaining a registration to dispense controlled medications.
4. The prescription must be consistent with all other [prescribing] requirements.

On March 1, 2023, a proposed rule was published in the Federal Register focused on telemedicine prescribing of controlled substances when the practitioner and the patient have not had a prior in-person medical evaluation. This proposed rule applies only in limited circumstances when the prescribing practitioner wishes to prescribe controlled medications via the practice of telemedicine and has not otherwise conducted an in-person medical evaluation prior to the issuance of the prescription. NHPCO submitted comments and will provide additional updates as they are finalized.

CDC Issues Guidance for Masking in Health Care Settings

NAHC

The Centers for Disease Prevention and Control (CDC) has issued revised guidance for Interim Infection Prevention and Control Recommendations for Healthcare Personnel During the Coronavirus Disease 2019 (COVID-19) Pandemic .

The guidance applies to all health care settings and provides a framework to implement select infection prevention and control practices based on their individual circumstances. Specifically, CDC added an appendix to assist facilities with how and when to implement broader use of  source control (masking).  CDC also announced that it will no longer be collecting information needed to track the community transmission rates of COVID-19.

There are several considerations that CDC addresses that will help guide when a broad use of masking in the healthcare settings should be implemented.

• The types of patients cared for in their facility.
• Input from stakeholders.
  • Reviewing plans with stakeholders including patient and family groups and healthcare personnel can help determine the most appropriate infection control practices for staff and patients.

• Facilities might tier their interventions based on the population they serve. For example, facilities might consider a lower threshold for action in areas of the facility primarily caring for patients at highest risk for severe outcomes (e.g., cancer clinics, transplant units). Home health and hospice agencies might consider establishing  policies for masking when caring for patients with a  high risk for contracting infectious diseases.

• Plans from other facilities in the jurisdiction with whom the facility shares patients.
  • Some jurisdictions might consider a coordinated approach for all facilities in the jurisdiction. Input from local hospitals and other healthcare providers can help inform the agency’s policy for masking.

• What data are available to make decisions.
  • Facilities and jurisdictions might have access to more granular data for their jurisdiction to help guide efforts locally. Agencies should work with their local  public health departments for community transmission data.

Unfortunately, with the end of the public health emergency, CDC will no longer receive data needed to publish Community Transmission levels for SARS-CoV-2. CDC will continue to collect and report SARS-CoV-2 hospital admissions data on the CDC COVID Data Tracker, although not as accurate as community transmission levels for COVID-19 surveillance.  These data continue to be available at the county level and are used by CDC to help the public decide when masking in the community should be considered.

CDC is in the early stages of developing metrics that could be used to guide when to implement select infection prevention and control practices for multiple respiratory viruses. Data on the exact metric thresholds that correspond with a higher risk for transmission are lacking. In addition, data from these systems are generally not available for all jurisdictions.