Four DALs for CHHAs, LTHHCPs, LHCSAs and MLTCs
The Department of Health (DOH) posted four Dear Administrator Letters (DALs) to the Health Commerce System (HCS) within the last seven days.
- DHCBS 15-03 - Home Health Aide Training Program (HHATPs) Requirements - Reminders and Requests for Information (due Thurs. April 30)
On Thurs., April 9, DOH posted the DAL which reminds home health agencies about two key requirements and to request evaluation information regarding their HHATPs. The two key requirements mentioned in the DAL are from the "Guide to Operation of a Home Health Aide Training Program," commonly referred to as the Guide. The first is to remind all HHATPs that they are required to have policies and procedures describing their quality management program and the annual evaluation of the training program (see pages 11 and 12). In the Guide, it states that program monitoring must be conducted on at least a quarterly basis; documentation of this monitoring must be included in the quality assurance minutes of the sponsoring agency. In addition, an annual evaluation report must be submitted to the sponsoring agency’s governing authority and to the applicable NYS Department of Health (NYSDOH) Regional Office with the re-approval application.
The Division of Home and Community Based Services is requiring all HHATPs to provide a copy of the 2014 or 2013 annual evaluation report by Thurs. April 30, 2015 to:
The second requirement, as described on page 14 of the Guide, states that all HHATPs must provide the appropriate regional office with a schedule of anticipated classes every six months (each Apr. 1 and Oct.1). Here is a form and instructions to transmit information on the training classes to the appropriate regional offices.
- DHCBS 15-04 - Electronic Plan of Correction (ePOC)
Next week, Fri. May 1, DOH will resume the implementation of the Electronic Plan of Correction application for home health agencies. This was previously discussed in June 2013, in DAL DHCBS 13-13. The ePOC application is accessible via HCS, please note that some HCS roles are new, such as a new Operator role, which represents a change in DOH policy.
In this DAL are numerous training material for your review, such as a recorded training webinar, PowerPoint presentation, an ePOC Quick Users Guide and an ePOC Facility User Manual.
- DHCBS 15-05 - CHHAs & LTHHCPs - Provision of Care Management Services to Managed Long Term Care Plan Enrollees
DOH responded to several questions brought forward by LeadingAge NY and other associations on how care management services can be provided by a Certified Home Health Agency (CHHA) or a Long Term Home Health Care Program (LTHHCP) through contractual arrangements with Managed Long Term Care (MLTC) plans without triggering federal Conditions of Participation (CoP). This has been an ongoing issue raised during the last two years at the Home and Community-based Care Workgroup meetings, as well. The workgroup sent a letter to CMS, which included this question. CMS and DOH have responded by clarifying this issue from the State Operations Manual (SOM) Parts 2180, 2180C, 2183, 2183.1, 2183.2 and 2183.3.
In the DAL it cites how to conduct care management as a "separate entity" and not triggering the CoPs. It also includes three parameters that must be followed and six distinctions for a separate line of business from a CHHA or LTHHCP. LeadingAge NY is reviewing this DAL and encourages members to contact us with your questions or concerns. We have reached out to DOH and requested a meeting to discuss this DAL and other issues from the last workgroup meeting.
- DHCBS 15-06 - Responsibilities of Home Care Providers related to Emergency Preparedness for Managed Care Enrollees
Again, DOH responded to several questions brought by home care providers and plans regarding roles and responsibilities during emergencies. In the DAL it cites the regulations to follow a previous DAL on emergency preparedness from May 2005, which states that home care providers may be required to provide daily updates to plans dependent upon their contracts, and requires agencies to have an "effective communication system through HCS for the purposes of emergency communication with the Department and to ensure a rapid response for information as requested by the Department." It also covers case management responsibilities.
LeadingAge NY will follow up on this DALwith DOH at our next meeting.
Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871