The federal declaration of the COVID-19 public health emergency will terminate on May 11, 2023. Due to the expiration of the federal COVID-19 public health emergency, the following will occur regarding Home Health Program flexibilities described in the MO HealthNet hot tips dated May 14, 2020 and April 17, 2020:
Plans of Care and Certifying/Recertifying Patient Eligibility: An advanced practice registered nurse who is working in accordance with State law, or a physician assistant who is working in accordance with State law may: (1) order home health services; (2) establish and periodically review a plan of care for home health services (e.g., sign the plan of care), (3) certify and re-certify that the patient is eligible for home health services. This will provide the flexibility needed for more timely initiation of services for home health patients, while allowing providers and patients to practice social distancing. This flexibility was made permanent. See the MO HealthNet Home Health Provider Bulletin dated August 24, 2022.
Initial Assessments: Home health agencies, as appropriate, can perform initial assessments remotely or by record review. This will allow patients to be cared for in the best environment for them while supporting infection control and reducing impact on acute care and long-term care facilities. This will allow for maximizing coverage if there are limited physician and advanced practice clinicians, and will allow those clinicians to focus on caring for patients with the greatest acuity. This flexibility will end on May 11, 2023.
Onsite Visits for HHA Aide Supervision: The onsite nurse visit is not required. This includes waiving the requirement for a nurse or other professional to conduct an onsite visit every two weeks to evaluate if aides are providing care consistent with the care plan, as this may not be physically possible for a period of time. This waiver also temporarily suspends the 2-week aide supervision requirement by a registered nurse for home health agencies, but virtual supervision is encouraged during the period of the waiver. This flexibility will end on May 11, 2023.
Occupational Therapists (OTs), Physical Therapists (PTs) and Speech and Language Pathologists (SLPs): OTs, PTs and SLPs may perform the initial and comprehensive assessment for all patients. The requirement that OTs, PTs and SLPs may only perform the initial and comprehensive assessment when only therapy services are ordered is waived. This modification allows an OT, PT, or SLP to perform the initial and comprehensive assessment for all patients receiving therapy services as part of the plan of care, to the extent permitted under state law, regardless of whether or not the service establishes eligibility for the patient to be receiving home care. OTs, PTs and SLPs are not permitted to perform assessments in nursing only cases. HHAs are expected to continue to match the appropriate discipline that performs the assessment to the needs of the patient to the greatest extent possible. On May 11, 2023, MHD will follow CMS’ guidance for Medicare related to this flexibility. Per CMS’ informational document titled “Home Health Agencies: CMS’ Flexibilities to Fight Covid-19”, CMS finalized changes to § 484.55(a) and (b)(2) to permanently allow occupational therapists to complete the initial and comprehensive assessments for patients, in accordance with Division CC, section 115 of CAA 2021.