Post-Acute Care

Overview

Home Health

Home health care is a formal, regulated program of care delivered by a variety of health care professionals in the patient’s home for the treatment of a medical condition, illness or disability. Home health is provided through certified home health agencies (HHAs).

As components of the post-acute continuum of care, HHAs provide essential health care services. This specialized support allows patients to remain at home when they would otherwise have to be admitted to a costly institutional setting, such as a skilled-nursing facility or hospital.

CHA’s Center for Post-Acute Care represents the interests of CHA member post-acute care providers,  including inpatient rehabilitation hospitals and units,  long-term acute care hospitals, distinct-part skilled-nursing facilities and home health agencies.  As a part of CHA, the Center for Post-Acute Care serves as the primary public policy arm of the hospital association for post-acute care issues. The center also advocates for hospital-based post-acute care services  in the federal and state legislative and regulatory arenas.

CHA News Article

CMS Provides Guides for Post-Acute Care and Hospice Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) has posted quality reporting program quick reference guides for several post-acute care settings, including long-term care hospitals, inpatient rehabilitation facilities, home health agencies and hospice. The guides include frequently asked questions, information on help desks and links to additional resources. 

CHA News Article

Home Health Agencies May Hire Accreditation Organization to Conduct Licensing Survey

A recent All Facilities Letter (AFL 17-20) from the California Department of Public Health (CDPH) states that, as of Oct. 1, home health agencies may expedite the licensing process by hiring a Centers for Medicare & Medicaid Services approved accreditation organization to conduct the initial state licensing survey, avoiding the current delay of three months to two years in initial application survey completion. If a home health agency chooses to hire its own accreditation organization and passes its initial survey, the CDPH Centralized Applications Unit will issue a six-month provisional license. More details on the process, as well as a list of approved accrediting organizations, are available in the attached AFL. 

CHA News Article

CMS Launches Jimmo Settlement Agreement Web Page
Provides clarification of “maintenance coverage standard” for therapy, skilled-nursing services

The Centers for Medicare & Medicaid Services (CMS) has developed a web page providing background and resource information on the January 2013 Jimmo Settlement Agreement, which clarified that the Medicare program covers skilled-nursing care and skilled therapy services under Medicare’s skilled-nursing facility, home health and outpatient therapy benefits when a beneficiary needs skilled care to maintain function, or to prevent or slow decline or deterioration (provided all other coverage criteria are met). The new web page provides access to various public documents related to the Jimmo Settlement Agreement, including frequently asked questions.

Overview

Hospice

Hospice provides comprehensive and interdisciplinary health care to terminally ill patients, as well as bereavement and support services to the patients’ loved ones. Patients receiving hospice care forgo curative treatments. Hospice care is provided through certified hospice programs, and may be delivered in any patient care setting, but is most often provided in the patient’s home.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective hospice health care services.
 

CHA News Article

CMS Provides Guides for Post-Acute Care and Hospice Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) has posted quality reporting program quick reference guides for several post-acute care settings, including long-term care hospitals, inpatient rehabilitation facilities, home health agencies and hospice. The guides include frequently asked questions, information on help desks and links to additional resources. 

CHA News Article

DHCS Releases Guidance to Medi-Cal Managed Care Plans on Providing Palliative Care

The California Department of Health Care Services (DHCS) has released the attached All Plan Letter (APL) informing Medi-Cal managed care health plans (MCPs) of their obligation to provide palliative care to Medi-Cal members, pursuant to Senate Bill (SB) 1004 (Chapter 574, Statutes of 2014).To fulfill the bill’s requirement that DHCS establish standards and provide technical assistance to MCPs for the delivery of palliative care, the department outlines its Palliative Care Policy specifying the minimum types of palliative care services MCPs must authorize when medically necessary for a Medi-Cal member who meets eligibility criteria. This APL advises MCPs that, effective Jan. 1, 2018, when a Medi-Cal member meets the minimum eligibility criteria for palliative care, MCPs must authorize palliative care without regard to age.

At a minimum, palliative care must include advance care planning, palliative care assessment and consultation, plan of care, palliative care team, care coordination, pain and symptom management, and mental health and medical social services. The APL further advises MCPs that they must have a process to determine the type of palliative care that is medically necessary or reasonable for eligible beneficiaries, and must have a large enough network of palliative care providers to meet their Medi-Cal members’ needs.

CHA News Article

MedPAC Issues June 2017 Report to Congress

The Medicare Payment Advisory Commission (MedPAC) released its June 2017 Report to the Congress: Medicare and the Health Care Delivery System. The document includes 10 chapters covering key issues facing the Medicare program and offers solutions to ensure the program’s continued viability. 

In its June report the commission continues its work, required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act, evaluating the feasibility of a unified prospective payment system (PPS) spanning post-acute care (PAC) settings (e.g., skilled-nursing facility, inpatient rehabilitation facility, long-term care hospital and home health agency). After determining a unified PPS is feasible in its 2016 report, the commission studied three implementation issues: a transition period with blended setting-specific and unified PPS rates, appropriate levels of aggregate PAC payments, and ways to address ongoing refinements to the system after implementation. MedPAC recommends that a unified PAC PPS be implemented beginning in 2021 with a three-year transition, and that aggregate payments should be reduced by 5 percent.

Overview

Inpatient Rehabilitation & Therapy Services

Medical rehabilitation focuses on improving or restoring functional independence for individuals with disabilities resulting from injury, illness or a medical condition.

Medical rehabilitation is provided at all levels of the health care continuum, including general acute-care hospitals, inpatient rehabilitation facilities (IRFs), skilled-nursing facilities, long-term-care hospitals, outpatient programs and home health agencies.Services may range from coordinated interdisciplinary programs to individual therapy disciplines.

CHA News Article

CMS Provides Guides for Post-Acute Care and Hospice Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) has posted quality reporting program quick reference guides for several post-acute care settings, including long-term care hospitals, inpatient rehabilitation facilities, home health agencies and hospice. The guides include frequently asked questions, information on help desks and links to additional resources. 

CHA News Article

Deadline for Submission of Post-Acute Care Quality Data Approaching
SNF Quality Reporting Program data submission extended to May 2018

Data for the inpatient rehabilitation facility and long-term care hospital quality reporting programs (QRPs) must be submitted to the Centers for Medicare & Medicaid Services by 11:59 p.m. (PT) on Nov. 15.

The reporting deadline for skilled-nursing facility (SNF) QRP data on measures has been extended and will have a single submission date of May 15, 2018, for calendar year 2017 data. SNFs are encouraged to review their data submission on at least a quarterly basis.

CHA News Article

CMS Formally Withdraws Three Proposed Rules, Including Part B Drug Model

The Centers for Medicare & Medicaid Services (CMS) formally has formally withdrawn a number of proposed rules, including the Medicare Part B Prescription Drug Model that was opposed by CHA and not finalized by the Obama Administration. In addition, CMS withdrew a proposed rule that would have specified qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. In comments on the proposed rule, CHA urged CMS to withdraw the proposal and is pleased to see the agency do so.

Finally, CMS also withdrew a proposed rule that would have revised certain conditions of participation for health care providers, conditions for coverage for suppliers, and requirements for long-term care facilities to revise certain definitions and patients’ rights provisions to ensure they are consistent with the Supreme Court decision in United States v. Windsor. CMS believes that a subsequent Supreme Court decision on same-sex marriage, Obergefell v. Hodges, “has addressed many of the concerns raised” in the original rule.  

Overview

Long-Term-Care Hospitals

Long-term-care hospitals (LTCHs) provide hospital-level care for medically complex, long-stay patients. LTCHs meet the same requirements as general acute-care hospitals, but have significantly longer average lengths of stay of 25 days or greater. LTCHs may be freestanding facilities or be co-located within hospitals, and treat a wide variety of conditions, including respiratory failure with ventilator dependency, infections, complex wounds and trauma.

CHA’s Center for Post-Acute Care represents the interests of CHA member post-acute care providers,  including inpatient rehabilitation hospitals and units,  long-term acute care hospitals, distinct-part skilled-nursing facilities and home health agencies.  As a part of CHA, the Center for Post-Acute Care serves as the primary public policy arm of the hospital association for post-acute care issues. The center also advocates for hospital-based post-acute care services  in the federal and state legislative and regulatory arenas.

CHA News Article

Deadline Extended for Waiver Program Addressing Home, Community-Based Services
Provider applications due Dec. 15

The California Department of Health Care Services has extended to Dec. 15 the application deadline for “waiver agencies” to provide long-term home and community-based services and supports to eligible Medi-Cal beneficiaries who would otherwise receive care in a long-term inpatient care facility. The Department has made significant changes to its former Nursing Facility/Acute Hospital Waiver by shifting the waiver’s administration from the state to the local level; the revised waiver is now known as the Home and Community Based Alternatives Waiver. This restructuring will allow organized health care delivery systems to administer the waiver at the local level and oversee the provision of comprehensive care management and home- and community-based services and supports within a contracted service area.

Applications for waiver agencies will be accepted through Dec. 15. Qualifying organizations may include managed care health plans, public hospitals, organized health care delivery systems, and city/county health or social services departments. Applicants are required to demonstrate they have the experience, organizational capacity and fiscal stability to meet participants’ needs over the waiver’s five-year term. 

CHA News Article

CMS Provides Guides for Post-Acute Care and Hospice Quality Reporting

The Centers for Medicare & Medicaid Services (CMS) has posted quality reporting program quick reference guides for several post-acute care settings, including long-term care hospitals, inpatient rehabilitation facilities, home health agencies and hospice. The guides include frequently asked questions, information on help desks and links to additional resources. 

CHA News Article

Deadline for Submission of Post-Acute Care Quality Data Approaching
SNF Quality Reporting Program data submission extended to May 2018

Data for the inpatient rehabilitation facility and long-term care hospital quality reporting programs (QRPs) must be submitted to the Centers for Medicare & Medicaid Services by 11:59 p.m. (PT) on Nov. 15.

The reporting deadline for skilled-nursing facility (SNF) QRP data on measures has been extended and will have a single submission date of May 15, 2018, for calendar year 2017 data. SNFs are encouraged to review their data submission on at least a quarterly basis.

Overview

Skilled-Nursing Facilities / Distinct Part Nursing Facilities

Skilled-nursing facilities (SNFs) have the staff and equipment to provide skilled nursing, medical management and therapy services to individuals, on a 24-hour basis, who do not require high-intensity services provided in the hospital setting.

CHA News Article

All Plan Letter Addresses Long-Term Care Coordination, Disenrollment

The Department of Health Care Services has released the attached All Plan Letter clarifying Medi-Cal managed care health plans’ requirements related to long-term care for beneficiaries. First, the letter describes the requirement that plans coordinate the care and placement of beneficiaries who require long-term care in certain facilities including skilled-nursing, subacute, pediatric subacute and intermediate care. The letter further clarifies that plans are required to initiate disenrollment when the provision of long-term care is no longer a contractual obligation for the plan, such as when a beneficiary requires long-term care for longer than one month after the month of admission.

The guidance also outlines requirements for submitting disenrollment requests, and reminds plans that they are required to provide all medically necessary covered services until the Department of Health Care Services approves the disenrollment.

CHA previously submitted comments on the draft All Plan Letter.

CHA News Article

Deadline for Submission of Post-Acute Care Quality Data Approaching
SNF Quality Reporting Program data submission extended to May 2018

Data for the inpatient rehabilitation facility and long-term care hospital quality reporting programs (QRPs) must be submitted to the Centers for Medicare & Medicaid Services by 11:59 p.m. (PT) on Nov. 15.

The reporting deadline for skilled-nursing facility (SNF) QRP data on measures has been extended and will have a single submission date of May 15, 2018, for calendar year 2017 data. SNFs are encouraged to review their data submission on at least a quarterly basis.

CHA News Article

New Version of RAI User’s Manual Available for Long-Term Care Facilities

As of Oct. 1, all certified Medicare and Medicaid nursing facilities are required to use the latest Resident Assessment Instrument (RAI) 3.0 Manual v.1.15 as a reference in completing the Minimum Data Set (MDS) 3.0. This version of the RAI user manual, published by the Centers for Medicare & Medicaid Services, incorporates new guidance, coding instruction, steps for assessments and clarifications for:

  • Overview, content and components of the RAI
  • The RAI assessment process, requirements, state designation and nursing home responsibilities
  • Overview of the item-by-item guide to the MDS
  • Care area assessments, and care planning guidance and directions
  • Medicare skilled-nursing facility prospective payment system eligibility criteria

More information is available in the attached All Facilities Letter 17-19.

Overview

Subacute Care

Subacute-care units provide a specialized level of care to medically fragile patients. Subacute patients are individuals who do not need acute care, but who are too ill to be cared for by most skilled-nursing facilities. Frequently, these individuals are ventilator-dependent or require frequent respiratory treatments. While subacute beds are licensed as skilled-nursing beds, they are reimbursed differently and are subject to additional staffing and patient criteria requirements.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective subacute-care services.

CHA News Article

CMS Issues Proposed Revisions to Minimum Data Set

The Centers for Medicare & Medicaid Services has proposed revisions, attached, to the Minimum Data Set, the data collection and reporting tool used in skilled-nursing facilities (SNFs). The revisions reflect the provisions of the recently released proposed rule for the SNF prospective payment system, and reflect changes and additions required by the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). Additional information and a summary of the proposed rule are available on the CHA website.

CHA News Article

CDPH Issues Guidance on Automated Drug Delivery Systems
Impacts nursing, skilled-nursing and intermediate care facilities

The California Department of Public Health (CDPH) has notified providers that, as of Jan. 1, new state legislation has reinstated facilities’ ability to use automated drug delivery systems that allow personnel to access multiple drugs and are not patient-specific in their design. However, these systems must have electronic and mechanical safeguards in place to ensure that the drugs delivered to the patient are specific to that patient. As detailed in the attached All Facilities Letter, facilities must obtain authorization from the Licensing and Certification Program prior to using this type of system. 

CHA News Article

CDPH Reports High Flu Activity in California
Reiterates guidance for long-term care facilities

The California Department of Public Health (CDPH) has issued the attached All Facilities Letter reminding providers that influenza activity in California remains high and is rapidly increasing. CDPH has received numerous reports of influenza outbreaks in health care facilities, particularly long-term care facilities and skilled-nursing facilities. The attached letter reiterates important infection control measures providers should be aware of and encourages facilities to follow infection control guidance from the Centers for Disease Control and Prevention if they experience an outbreak. If an outbreak occurs, facilities should avoid new admissions or transfers to units with symptomatic residents. Facilities should also note the broad impact these outbreaks, and their effect on patient admissions, can have across the continuum of care.

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