For Our Alabama Hospice Clients
From the Alabama Hospice and Palliative Care Organization
COVID-19 UPDATE
As hospices, like the rest of the country, grapples with COVID-19, AHPCO is sharing information.
While CMS has lifted rules and is now allowing tele-medicine in certain States and practices such as Home Health, we have no firm guidelines as to what this means for Hospice. AHPCO is passing along updates from the Alabama Department of Public Health with our membership in addition to the latest update from NHPCO.
From Lisa Teel, President of AHPCO
Due to the fact that there is no current written guidance from regulatory entities related to COVID-19 and visit frequencies, Comfort Care Hospice has adopted the practices outlined in this update until additional clarification is obtained. We are attempting to visit all patients who reside in a nursing home at least once a week, and this is thought to be best practice if we are still allowed in the facility. Of course, this is not possible in many of our Nursing Facilities. Therefore it is recommended to call weekly so we can update the Plan of Care, keep up with medication changes as well as durable medical equipment and supply needs.
Our Director of Clinical Services, Glenda Caffee, called Tonya Blankenship with the Alabama Department of Public Health two weeks ago to discuss the above plan. She stated that ADPH is well aware of the limitations and challenges with continued hospice care in nursing homes given the outbreak of COVID19 and affirmed this plan would be acceptable given that adequate documentation is present in the medical record.
According to conversations with ADPH about the frequency of nursing visits, visits every 14 days should not be an issue especially if the patients/families request reduced visits. According to Tonya Blankenship, it is going to all depend on our documentation. If at all possible, they expect us to do nursing recertification visits and F2F visits unless telehealth is allowed in the future (pending right now for the State of Alabama but allowed in other States).
In cases where we cannot enter a nursing facility or home in rare circumstances, Charles Canaan reports that Palmetto GBA is “waiting on CMS to give us an answer. Right now do what you can (phone calls, etc.)”.
Documentation Tips Per ADPH & Best Hospice Practices:
Document clearly, at least weekly, regarding the communication with the nursing facility and the status of the hospice patient, including any changes.
Document with whom you spoke, the questions you asked and the responses received. Questions asked should reflect the current status of the patient to include, but not limited to, changes in overall condition, pain, appetite, activity, mood, weight, decline, etc. (anything related to the patient’s hospice diagnosis and overall status of the patient).
It is of upmost importance that we document the facility is under quarantine for COVID-19 and that we have ongoing communication with the facility and with the family as this may be the only consistent updates that the family receives. For continuity, it is best practice to have the same person call each week if at all possible. Be certain to follow your own agency’s established policies, procedures and processes.
The best guidance is for you to Document, Document and Document…be specific about the circumstances of why you are not able to see the patient such as that the nursing facility is on lockdown and not allowing any hospice personnel in the building due to COVID-19 and include what measures you are taking to stay updated on the patient’s status. Call at least weekly and let the facility know that you are updating the family which will in turn be beneficial to the facility.
Communication and documentation will be key during this unprecedented time.
Please take steps to protect your staff if you have not already done so by limiting the number of employees in the office to 10 or less with distances of 6 feet or more apart. Screen all employees each morning for symptoms of COVID-19 and include any possible exposure. If you are in area which is considered a “hot spot”, it is also recommended that you take temperatures. This screening would apply to any visitors and vendors, and most vendors/supply companies are leaving packages at the door and not entering hospice offices.
If your agency has a need for Personal Protective Equipment (PPE), some hospices have been able to obtain a limited amount through their local Emergency Management Agency (EMA).
If your hospice agency has any recommendations or solutions to issues related to COVID-19, we ask that you share them with AHPCO.
We are doing our best as an association to monitor updates and additional guidance and will pass information on to our members as we receive it.
3/24/2020 NHPCO COVID-19 UPDATE
NHPCO has created this update for hospice and palliative care providers to share the most recent news and helpful links regarding this ongoing public health crisis.
"You are there for your community. NHPCO is there for you.”
Policy Updates
Senate Close to a Deal on Nearly $2 Trillion Third COVID-19 Emergency Stimulus Package
The broad legislative package includes a $500 billion fund designed to lend money to corporations that have been hit hard by the coronavirus pandemic, food stamps, worker protections, other economic stimulus measures, as well as some healthcare related provisions. Negotiations are ongoing and a vote is expected tonight or tomorrow morning and includes at least two provisions that directly impact hospice providers including, the elimination of the sequestration 2% cut for Medicare hospice providers and a provision to allow hospice face-to-face encounters to be conducted through telehealth. A third provision, an emergency fund for health care providers for COVID-19 related expenses is also being negotiated and could be at least $100 billion or more. After Senate passage the House will likely pass the measure and send to President Trump for his signature. At the same time the House will continue to work on a 4th COVID-19 related piece of legislation.
Face-to-face hospice telehealth provision. The draft legislation allows face-to-face encounters for recertification for hospice care to be completed using telehealth during the emergency period.
Proposal to suspend sequestration cuts. Draft legislation also includes the temporary suspension of the 2 percent sequestration cut to hospice, beginning on May 1, 2020 and ending on December 31, 2020.
CMS Answers NHPCO Questions on Flexibility
NHPCO requested additional written clarification on flexibilities for hospice. Today (3/24/2020), we received the following email from CMS:
We [CMS] are aware of the need to issue additional guidance to hospices about the flexibilities already included in the CoPs when it comes to determining on a case-by-case basis how a visit should be made. As we [CMS] stated on the call [with NHPCO], the hospice CoPs don’t specify how or how often direct clinical visits are made. Hospice providers are required to provide services that meet the needs of the patient based on the plan of care that is person-centered and individualized. CMS encourages hospices to address these issues on a case by case basis and make sure to document how the hospice is meeting the goals of care in a safe and appropriate manner. We are working on issuing revised guidance, but do not have a projected release date at this time. I hope this can help you reassure hospice providers that we hear their concerns and are committed to working with them to get through this public health emergency. As always, please reach out to us when we can be of service.
CMS Issues Guidance on Survey Process During COVID-19
CMS Quality, Safety and Oversight Group (QSOG) issued guidance on the survey process for all providers during the national emergency. Standard surveys for hospices will not be authorized, it reiterates the visitor restriction and includes hospice facilities, reiterates the allowance for hospice workers in nursing homes and also states that if a state has established more restrictive criteria, the provider must follow the more restrictive guidance.
NHPCO Requests Suspension of TPE from MACs
NHPCO has been in communication with the three Medicare Administrative Contractors (MACs) with a request to suspend Targeted Probe and Educate (TPE) efforts for hospice providers for the duration of the COVID-19 national emergency. The MACs have been in discussion with CMS on this suspension and have conveyed to us that CMS must make the final decision and convey that suspension to the MACs. We have also requested this suspension from CMS.
Provider Updates
OIG Alert on COVID-19 Fraud Schemes
The OIG just released a fraud alert regarding fraud schemes, including marketing fake COVID-19 test kits and unapproved treatments through telemarketing calls, social media platforms, and door-to-door visits. This alert has general information about these schemes and how to protect yourself and your community against bad actors. Read full alert: COVID-19 Fraud Alert.
Resources
Quick References Regarding “Rumor vs. Truth” on COVID Treatments
Many thanks to Bridget McCrate Protus, PharmD, and Director of Drug Information with Optum who has developed and is sharing quick references regarding "Rumors vs. Truth" on treatments related to COVID-19, along with a list of governmental, organizational, and some publisher resources with hyperlinks directly to the COVID-19 collections and a brief description of content available.
Reminder: COVID-19 Executive Dialogue on March 25
If you have not already registered for the free webinar, COVID-19 Executive Dialogue, that NHPCO is offering on Wednesday, March 25 from 2:00pm – 4:00pm ET, please do so as soon as possible. If you’re not able to participate in the webinar that is open to members and non-members, the archive recording will be added to the nhpco.org/coronavirus page as soon as it is available.
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