Encore Keynote – February 2023

Brain Fitness

February is National Senior Independence Month, and at Encore Rehabilitation, we strive to consider all aspects of independence with the people we serve. When we think of independence, aging, and our health, what areas of health first come to mind? It’s likely our initial thoughts are physical health and fitness. As we age, if we are still able to get dressed and walk to where we need to go, we must be doing ok, right? Not necessarily. There is more to physical health and fitness than many may think. When assessing the health and wellness of our residents, we should be considering residents’ brain fitness as a part of the total package for their independence. Since independence can mean different things to different people, it is important to consider individual preferences, individual cultures, values, and the level of independence our residents wish to achieve or maintain.

Physical health and fitness certainly have a direct impact on our brain health and should be promoted in our care communities to help individuals maintain their independence in whatever setting in which they reside.

Consider the impacts of:

To maintain brain fitness, we must consciously address these areas. There are many “brain games” out there that can be accessed for free to maintain attention, memory, and problem-solving. If working on brain fitness is the goal, then practicing the desired functional tasks is what must be done.

Examples:

Maintaining functional levels of independence is vital to our residents’ quality of life. As healthcare providers, we should be positioning ourselves to help the people we serve maintain their highest level of both physical and cognitive independence.

Diagnosis Coding Tip:

Initial Encounter vs. Subsequent Encounter Diagnosis

A recent trend in claim reviews reflects scrutiny when claims include coding for an Initial Encounter diagnosis (when the 7^th character of the ICD code is ‘A’).  While the use of an Initial Encounter diagnosis can be appropriate based on the documentation, providers may benefit from seeking physician clarification to determine if the most relevant condition is captured and evaluate if criteria is present instead for a subsequent encounter diagnosis (7^th character of the ICD code is a ‘D’).

Last diagnosis code character ‘A’ = ASK the physician

Initial encounters occur during the time a patient is receiving active treatment for the injury/cause, and may extend to services following more than just the initial visit.  Subsequent encounter episodes follow the active treatment, during which the patient receives routine care for the injury while they recover or heal.  As always, the appropriate condition would be coded based on the physician’s clinical decision and must be documented in the medical record per the CMS guidelines.

COVID-19 Public Health Emergency (PHE) Set to End May 11

Late Monday, January 30, 2023, President Biden announced that the Administration will end the national Public Health Emergency (PHE) on May 11, 2023. The current PHE is scheduled to end on April 11, 2023; however, President Biden announced yesterday that it will be extended one extra month and then end.

The national emergency, which is a separate declaration from the US Department of Health & Human Services’ (HHS’) public health emergency, is currently set to expire on May 1 with the PHE set to expire on May 11, 2023. President Biden will extend the national emergency for an additional 10 days and bring both emergencies to a conclusion on May 11, 2023. This wind-down aligns with the Administration’s previous commitments to give at least 60 days notice prior to termination of the PHE.

A link to the official White House Statement of Administration Policy (SAP) regarding a bill being considered by the US House of Representatives this week to end the PHE is available here.

Telehealth Implications

Last year’s Consolidated Appropriations Act of 2023 (CAA 2023), which was signed into law in December 2022, extended telehealth flexibilities allowed during the PHE. The law effectively decoupled telehealth flexibilities from the PHE such as the law allows rehabilitation therapists to use telehealth through December 31, 2024.

Medicaid Implications

Although the Medicaid redeterminations process was also decoupled from the PHE by the CAA 2023, states are set to restart normal redetermination processes soon – some as early as February 2023. The continuous coverage requirement also ends on March 31, 2023 and states can begin dropping Medicaid beneficiaries from coverage as soon as April 1, 2023.

States have 12 months to begin redetermining each beneficiary’s eligibility and 14 months to complete the process; however, they’re required to process fresh renewals for each beneficiary, meaning Medicaid staff cannot use eligibility information obtained before February during the unwinding period.

The CAA 2023 also decoupled the 6.2% Federal Medical Assistance Percentages (FMAP) bump to the federal Medicaid match rate from the PHE and provided for a phase-out of the enhanced funding over nine months for states that adhere to certain conditions. The enhanced FMAP will decline over time beginning April 1, 2023, at which time the FMAP enhancement will be reduced to 5%. Beginning July 1, 2023, the FMAP enhancement will be reduced to 2.5% and then down to 1.5% beginning October 1, 2023. Effective January 1, 2024, the FMAP enhancement will expire altogether.

Nursing Home Implications

As ADVION has reported, CMS began phasing out many nursing home COVID-19 waivers last year, including the temporary waiver for nurse aide training. The flexibility was meant to improve staffing during the pandemic by letting facilities employ temporary nurse aides for more than four months without certified nurse aide training, but CMS allowed the waivers to end in early October 2022 and instead approved waivers in 15 states, which last no longer than the end of the PHE.

The waiver of the three-day hospital inpatient stay requirement and the spell of illness for skilled nursing care also  is tied to the end of the PHE, and therefore these policies also will end with the PHE on May 11, 2023.

Health IT Implications

The unwinding of the PHE will mean a return to rules, regulations and operations that may have been suspended during the COVID-19 PHE. For health IT developers – whether serving providers, facilities or state agencies – the unwinding of the PHE may mean reprogramming or reconnecting services.

We know from our health IT vendor members that waivers and other temporary policies that affect facility operations and the software and health IT systems that support them will affect health IT developers’ roadmaps. To its credit, CMS has provided its own roadmap, which may offer helpful insights for the unwinding of the PHE. The agency also issued guidance to states, Top 10 Fundamental Actions to Prepare for Unwinding and Resources to Support State Efforts, which can be found on CMS’ Medicaid Unwinding webpage. CMS’ points “3. Implement and strengthen automated processes” and “4. Engage system vendors to identify changes, start planning, and perform robust testing” may be of particular interest to our health IT members.

ADVION understands that the end of the PHE will bring enormous change to the way your businesses have operated over the last three years, and we stand ready to monitor, provide updates, and work with you along the way to make sure that this transition is as smooth as possible.

Source: Advion

REMINDER:

The Skilled Nursing Facility (SNF) Provider Preview Reports have been updated and are now available.

These reports contain provider performance scores for quality measures, which will be published on Care Compare and Provider Data Catalog (PDC) during the April 2023 refresh.

Providers have until February 16, 2023, to review their performance data. Corrections to the underlying data will not be permitted during this time. However, providers can request Centers for Medicare & Medicaid Services (CMS) review of their data during the preview period if they believe the quality measure scores that are displayed within their Preview Reports are inaccurate.