COVID-19 Public Health Emergency (PHE) Expiration and Home Health Surveys

Home health surveys

The Public Health Emergency (PHE) that was put in place in response to the COVID-19 pandemic has ended, and home health surveys have resumed. This means that home health agencies will need to be prepared for a number of changes, including increased scrutiny from CMS, new requirements, and increased documentation.

In March 2020, the Center for Medicare & Medicaid Services (CMS) suspended survey activity for selected non-emergency state survey inspections to allow inspectors to prioritize the most serious health and safety threats like infectious diseases and abuse. But now that PHE has ended, CMS is back in full force. Many home health agencies are now due for surveys.

Regulatory waivers and flexibilities

CMS was allowed to issue several temporary emergency statutory and regulatory waivers and flexibilities to help providers respond to the COVID-19 Public Health Emergency (PHE) and focus on preventing the spread of COVID-19. 

But since the PHE has concluded, the Centers for Medicare & Medicaid Services (CMS) has released a guide for the expiration of the COVID-19 Public Health Emergency (PHE). 

Waivers that will end upon the conclusion of the PHE are:

  • Initial Assessments 

  • OT, PT, SLP Initial Assessments for all Patients

  • Detailed Information Sharing for Discharge Planning 

  • Onsite Visits for HHA Aide Supervision

  • Clinical Records 

  • OASIS Reporting

  • Quality Assessment and Performance Improvement (QAPI)

Home Health Surveys Resume After PHE

The Public Health Emergency (PHE) that was put in place in response to the COVID-19 pandemic has ended, and home health surveys have resumed. This means that home health agencies will need to be prepared for a number of changes, including:

  • Increased scrutiny: The Centers for Medicare and Medicaid Services (CMS) is likely to be more closely scrutinizing home health agencies in the wake of the PHE. This means that agencies will need to be prepared to demonstrate that they are meeting all applicable standards of care.

  • New requirements: CMS may also implement new requirements for home health agencies. For example, CMS may require agencies to implement new infection control measures or provide additional training to their staff.

  • Increased documentation: Agencies will need to be prepared to provide more documentation to CMS in support of their compliance with all applicable standards of care. This documentation may include things like care plans, progress notes, and discharge summaries.

Home health agencies can prepare for the resumption of home health surveys by taking the following steps:

  • Review their policies and procedures

Agencies should review their policies and procedures to ensure that they are in compliance with all applicable standards of care.

  • Provide training to their staff 

Agencies should provide training to their staff on the new requirements and expectations that CMS is likely to have.

  • Create a system for tracking and documenting compliance

Agencies should create a system for tracking and documenting their compliance with all applicable standards of care. This will help them demonstrate their compliance with CMS during a survey.

The resumption of home health surveys is an important opportunity for home health agencies to demonstrate their commitment to quality care. Taking the steps outlined above can help agencies prepare for the resumption of surveys and ensure that they are in compliance with all applicable standards of care.

In addition to the above, home health agencies can also take the following steps to improve their chances of passing a survey:

  • Make sure that all staff are familiar with the agency's policies and procedures.

  • Create a culture of safety and quality within the agency.

  • Be proactive in communicating with CMS and other regulatory agencies.

  • Invest in staff training and development.

  • Maintain accurate and complete documentation.

Preparation is Key

Now that PHE has ended, many home health agencies due for a survey, need to prepare to ensure compliance with regulations and guidelines set forth by the governing bodies. Surveys evaluate the agency's adherence to safety protocols, quality of care, and overall operational effectiveness. Being well-prepared shows that agencies are committed to providing high-quality services

For over 8 years, QAnnovate has been helping home health agencies prepare for surveys through specialized clinical documentation quality assurance - a solution to help home health agencies deliver the highest quality of care to their patients. Contact us today for a FREE trial.