On May 1^st, the Centers for Medicare and Medicaid Services (CMS) issued memorandum QSO-23-13-ALL, Guidance for the Expiration of the COVID-19 Public Health Emergency (PHE), addressing provisions for several health care provider facilities and agencies, including Certified Home Health Agencies (CHHAs) and Hospices. For general provider and skilled nursing facility (SNF) issues addressed in the guidance, please see this Intelligence article.

Provisions pertinent to CHHA and Hospice providers:

• Remote Initial Assessments: Waiver ends with the conclusion of the PHE.
• Occupational Therapists (OTs), Physical Therapists (PTs), and Speech Language Therapists Performing Initial and Comprehensive Assessment for All Patients (for patients receiving therapy services as part of the plan of care): This provision was included in the Calendar Year (CY) 2022 Home Health Prospective Payment System (PPS) Final Rule and finalized in federal regulation. It is unclear whether this provision is authorized under NYS law.
• Detailed Information Sharing for Discharge Planning: Waiver ends with the conclusion of the PHE.
• Waiver of Onsite Visits for Home Health Aide Supervision: Waiver ends with the conclusion of the PHE; see specific provisions for alternatives permitted.
• Patient Copy of Clinical Records: Waiver ends with the conclusion of the PHE.
• Outcome and Assessment Information Set (OASIS) Reporting Timeframe: Waiver ends with the conclusion of the PHE.
• Hospice Comprehensive Assessment Timeframe: Waiver ends with the conclusion of the PHE.
• Hospice Aide Competency Testing Allowing Use of Pseudo-Patients: Now allowed and includes additional provisions.
• Waiver of Certain Non-Core Services: Ends with the conclusion of the PHE.
• Narrowed Quality Assessment and Performance Improvement (QAPI) Requirements for Home Health Agencies and Hospices: Ends with the conclusion of the PHE.

Please see the QSO for specific details.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871