NAHC Hurricane Relief Task Force Advances Action Plan

FOR IMMEDIATE RELEASE: DATED INFORMATION
Contact: Richard Brennan, Jr., Director of Communications
National Association for Home Care & Hospice
Phone: 202-547-7424
pr@nahc.org

In the wake of the hurricane Katrina, NAHC has created a Task Force to coordinate the industry's response to the devastation caused by the storm. NAHC President Val J. Halamandaris appointed Barbara Citarella, President of RBC Limited and NAHC Vice President for Regulatory Affairs, Mary St. Pierre to co-chair this Hurricane Relief effort otherwise known as HRTF.

The first meeting of the Task Force took place by phone on Wednesday of this week. The HRTF set forth an action plan which includes many steps which have been implemented as of Thursday, September 1. Val J. Halamandaris sent two letters, one to HHS Secretary Mike Leavitt and another to CMS Administrator Mark McClellan, M.D. At the same time, Mary St. Pierre approached her contacts at the CMS Regional Office in Dallas and with Palmetto the Medicare fiscal intermediary which serves the region.

The Task Force agreed on several steps related to State and the Federal Government.

1. Petitioning the Governors
   
   The group agreed based on prior experience that it was important to get the Governors to issue an executive order which:
   
   
   1. Classifies home care personnel as emergency responders. (This will give them access to restricted areas and access to patients.)
   2. Waives state licensure requirements so that personnel (doctors, nurses, health care aides) who are licensed in other states can work legally in the States of Louisiana, Alabama and Mississippi and be paid to do so. (Under some state laws medical personnel may work for up to 30 days in a state where they are not licensed if they have a license and a reciprocal arrangement from another state and if they volunteer.
   3. Ask that home care personnel be placed at the top of the list if there is rationing or limited access to gasoline.
   
   Letters to this effect have been written to the respective Governors.
   
   
2. Petitioning the Department of Health and Human Services and the Centers for Medicare and Medicaid Services.
   
   The task force suggested CMS be approached for relief from certain Medicare Conditions of Participations as follows in these excerpts from the September 1 letter from Val J. Halamandaris to Commissioner Mark McClellan asking him to:
   
   1. Suspend the comprehensive assessment and OASIS requirements. This would apply in the immediately affected geographic areas of Louisiana and Mississippi and whenever an HHA assumes the care of displaced patients. It would allow home health agencies to more quickly deliver needed treatments based on medical triage and initial assessment.
   2. Suspend OASIS transmission requirements. Staff would be allowed to dedicate more resources to direct patient care through the suspension of this requirement.
   3. Suspend any geographic service area limitation consistent with any applicable state requirements. Currently, HHAs and hospices may be subject to service area limitations within the scope of their Medicare participation. A suspension of such limitation will allow out-of-area providers to serve areas where the hurricane has lead to the closure of local HHAs and hospices.
   4. Allow Nurse Practioners, Clinical Nurse Specialists, and Physician Assistants to establish plans of care and certify a patient's care plan provided that the action is within the scope of state licensure. This will extend the range of caregivers available to patients and make physicians available to meet other, potentially more pressing duties.
   5. Suspend the requirement that one discipline of home health services be provided exclusively through employees. This will create some flexibility in the delivery of services to accommodate chaotic needs
   
   In addition CMS was asked for relief from certain payment rules
   
   1. Suspend the "residence" component of the homebound requirements by allowing the delivery of home health services at any site of temporary residence. This would include a residence that is a nursing facility or hospital provided the patient is otherwise not at such level of care when the patient is using the facility as a medical shelter.
   2. Suspend the application of Partial Episode Payment (PEP) for patients displaced to other HHAs due to the hurricane.
   3. Suspend the 14 day payment floor on claims payment timing for the Gulf Coast HHAs and hospices affected. This will aid in providing wages to staff and bringing the providers into operation.
   4. Suspend consolidated billing requirements. This would allow patients to obtain needed services and supplies from any available source where the HHA is unable to provide the full range because of the disaster.
   5. Suspend electronic billing requirements. While most HHAs and hospices may maintain this capability despite the hurricane through the use of third-party services, some smaller providers may not have such option

Where do we go for more information?

The National Association for Home Care & Hospice has established a special section on its website to help keep people informed. To access it go to www.nahc.org. The Louisiana Association for Homecare has placed important facts on its website http://www.hclanet.org.