REVISED Guidance for Home Care Agencies, Home Health Care Agencies and Hospices During COVID-19 Pandemic
May 20, 2020
The
Department of Health (Department) has received questions regarding the
operation and management of home care, home health care, and hospice
agencies in relation to the COVID-19 health emergency. This additional
information is provided to help you understand and operationalize the
guidance provided by the Governor and the Secretary of Health as well as
the Centers for Medicare and Medicaid Services (CMS) and the Centers
for Disease Control and Prevention (CDC). The Department provides the
following guidance, which supersedes the information issued on March 21,
2020:
1.
Life-Sustaining Business
Under
the PA Health Care Facilities Act Chapter 8 Section 802.1 a home
care agency/registry is identified as a 'health care facility' as the
agency provides clinically related health care services. Home care
agencies/registries are life-sustaining services under the Governor's
and Secretary of Health's business closure orders issued on March 19,
2020.
2.
Access to Nursing Homes for Hospice Workers
Federal
guidance issued on March 13, 2020 included hospice workers among those
caregivers allowed access to nursing homes while restricting other
visitation. Hospice workers must adhere to the
CDC guidelines for infection control for health care workers.
3.
Personal Protective Equipment (PPE)
Refer to
HAN 492, Universal Masking of Healthcare Workers and Staff in Congregate Care Settings, for guidance on PPE, as well as the
Department's Fact Sheet.
4.
Service Plan Changes, Timing, Utilization Due to Changes
The
Pennsylvania Department of Human Services (DHS) has incorporated
significant flexibility into the Community HealthChoices (CHC) managed
care program and in the home and community-based OBRA waiver within
fee-for-service. DHS issued guidance to advise the managed care
organizations and OBRA fee-for-service providers of these new
flexibilities. The guidance can be found here:
CHC Waiver and
OBRA Waiver.
Services
may not be reduced in service plans, unless requested by the
participant or their representative. Additionally, because not all
services can be provided during the COVID-19 pandemic and certain
services may need to be prioritized, additional flexibility was added to
prior authorization requirements and service plan additions or changes.
Providers should work with their
managed care organizations and the Office of Long-Term Living's
Participant Services Review Unit to request this flexibility and have
service plans and service configuration altered to support participant
needs.
5.
Missed Visit Reporting for Home Care Agencies When the
Direct Care Worker (DCW) Is Ill or Is Turned Away from the Consumer's
Home
The
home care agency should evaluate capacity to meet participant's service
needs in the event staffing is impacted by the COVID-19 pandemic. If
sick, the DCW should not be working and the home care agency is
responsible to find a replacement for the DCW. If the agency is unable
to find a replacement they should notify the CHC managed care
organization or OBRA waiver service coordinator and assist in
implementing the participant's emergency back-up plan.
If
a DCW is turned away from a consumer's home, the DCW should document
that in the consumer's medical record and report the refusal of service
to the CHC managed care organization or service coordinator. Per the
Department of Human Services, managed care organizations have been given
instructions on special reporting during this period for missed
shifts. Please consult with the managed care organizations for specific
instructions.
6.
Ensuring Critical Needs Are Met During Periods of Staff Shortages
The
Department expects that each agency's Emergency Preparedness Plan
includes provisions related to staff shortages that may include
contracts/agreements with other home care/home health care/hospices or
staffing agencies. Agencies should review, assess and prioritize their
patients/consumers based on the complexity and frequency of their care
needs. Modifications of assignments based on care needs and frequency
should be made from most complex to simpler personal care tasks.
Notifications and explanations related to changes need to be made with
patient/consumer/responsible party.
Additionally, agencies need to ensure that participant/consumer files include emergency back-up supports that are identified and are current. For those patients/consumers
utilizing services in Community HealthChoices or the OBRA Waiver
program, agencies must collaborate with the designated managed care
organization or Service Coordinator and ensure back-up supports are
identified.
For participants enrolled in
Community HealthChoices or the OBRA Waiver program, agencies should
work with managed care organizations and Service Coordinators on service
prioritization of participants and to support agency efforts to
identify appropriate resource allocation.
-
Extension of Service Areas for Home Care Agencies
-
Interviewing of Applicants for Direct Care Workers for Home Care Agencies
Face-to-face
interviews with applicants for employment are temporarily suspended.
Agencies may conduct telephonic or virtual interviews with applicants.
-
Pre-employment Health Screening
- The requirement for an initial baseline 2 step Mantoux skin test for tuberculin skin testing is temporarily suspended.
- All applicants must complete an individual
risk assessment and
symptom evaluation prior to hire.
- Any
new employee who does not provide evidence of a Mantoux skin test
within the previous 12 months must, as a condition of employment,
receive the tuberculin skin test as soon as possible following
termination of the Governor's COVID-19 Disaster Declaration.
-
Supervisory Registered Nurse (RN) Visits in Home Health Care Agencies
RN
onsite supervisory visits to the patient's residence at least every two
weeks are temporarily suspended. Telephonic or virtual visits will be
permitted to meet the intent of the regulation.
-
Use of Certified Registered Nurse Practitioners (CRNP) and Physician Assistants (PA) in Home Health Care Agencies
CRNPs
and PAs may order services for home health care agencies based on their
professional licensure under the applicable State Boards in the Bureau
of Professional and Occupational Boards.
With
the Governor's authorization as conferred in the Proclamation of
Disaster Emergency issued on March 6, 2020, certain regulatory
provisions have been waived or suspended that would have imposed an
impediment to implementing this guidance. Those suspensions can be
found on the Department of State's (DOS)
website and will remain in place while the proclamation of disaster emergency remains in effect.
RESOURCES
CMS:
https://www.cms.gov/files/document/qso-20-18-hha.pdf
CDC:
https://www.cdc.gov/infectioncontrol/guidelines/healthcare-personnel/index.html
Department:
https://www.health.pa.gov/topics/disease/Pages/Coronavirus.aspx
DOS Waived and Suspended Licensing Regulations:
https://www.dos.pa.gov/Pages/COVID-19-Waivers.aspx