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Posts tagged ‘Haydel Consulting Services’

Poor, Black People Have Worse Home Health Care Outcomes

An article came across my desk last week suggesting that Poor and Racial Minorities have Worse Home Health Care Outcomes.  If this surprises you, please stop reading and surrender your nursing license now.

If you read further, the article clarifies the Racial Minorities as Black even though the OASIS data set collects information on American Indians, Alaska Natives, Asians, Hispanic and Latinos, Native Hawaiian or Pacific Islanders as well as white patients.  So essentially, what the article is stating that if you are Black or poor, your health outcomes are worse.

Nurses know that African Americans are predisposed to certain diseases and conditions.  Hypertension and diabetes come to mind immediately. Nearly 42% of Black men and more than 45% of Black women aged 20 and older have high blood pressure.

It is the sequelae of those illnesses that disproportionately affect the black community.  This is where economics comes in and skews the healthcare received by Black people to an unacceptable degree.  Specifically, consider the following statistics:

  • Blacks are up to 2.5 times more likely to suffer a limb amputation and up to 5.6 times more likely to suffer kidney disease than other people with diabetes.
  • Strokes kill 4 times more 35 to 54-year-old black Americans than white Americans. Blacks have nearly twice the first-time stroke risk of whites
  • Cancer treatment is equally successful for all races. Yet Black men have a 40% higher cancer death rate than white men. Black women have a 20% higher cancer death rate than white women.

Additionally,

  • Black Americans are half as likely to get flu and pneumonia vaccinations as white Americans.  See last week’s blog post.

This information is obtained from an article on WebMD

There are so many reasons for these disparities that the study is almost useless to the home health industry.   So maybe the answer is to do what we always done – assess the individual needs of our patients and plan care accordingly.  But sometimes in our effort to be ‘color blind’ factors are overlooked that are closely correlated with being Black and poor in the USA.

About 24 percent of Black people cannot read past a basic level compared to 14 percent White people.  This information is not part of the OASIS dataset and probably shouldn’t be because the time and skills to assess reading ability are not available to us.  There are ways around illiteracy as most nurses know but they take time.  Take your time and be creative.  Send us an account of how your teach patients who cannot read.

Patients younger than 62 who are referred to you may have Medicaid as a primary payor.  In some states, Medicaid provides second rate health care encouraging the use of Emergency Room services when the patient is unable to wait for an appointment set in the distant future.  Medicaid approvals for some medications take time.  We can’t do anything about how the Medicaid system works but we can help the patients navigate the maze.  The truth is that we should be able to treat patients the same regardless of payor source but that ship sailed a long time ago.  If you want to be effective, you must know how the Medicaid system in your state functions.

Poverty and crime have an enduring relationship that isn’t likely to end soon.  Even though you are Wonderwomen and Supermen, you are not able to flash your badge and arrest the bad guys.  Consider the constant stress of living in a home where violent crime is common and how that might affect a patient.  When family members are addicts, patient medications may be diverted leaving a patient in pain unless they want to report a loved one to the police.  I have seen doors with multiple locks leaving me to wonder if there is an escape route in the event of a fire.

In rural areas, crime may not be a problem but the expense of getting to a physician’s office may be out of reach.   Family members may be willing to drive the patient but if they work, they might lose an entire day’s wages.  In these cases, it is possible that truly diligent assessments along with detailed reports to the physician may occasionally eliminate the need for an office visit.

Cheap food is frequently not on cardiac or diabetic diets.  Plus it adds body weight complicating pretty much every disease or condition.  The fact is that poor people eat cheap food and patients who cannot read are unable to follow that food list you gave them, anyway.

As much as we would like to, we cannot teach the world to read, fix Medicaid or reduce crime.  Driving patients to the physician’s office is impractical and basically a bad idea for reasons that would fill another blog post.  You can’t even plant a garden in their backyard to provide vegetables.

We have to look for allies.  Every agency should have a list of community services that can assist us in improving our patient’s’ chances of becoming a little more independent.   It should be reviewed regularly and distributed to all nurses.  Meals on Wheels isn’t the only service available.

We also need to realize that while outcomes are important, there are some things we cannot control.  When someone has untreated hypertension resulting in a stroke prior to admission, it is unreasonable to expect the same good outcomes that result when a patient is referred after being diagnosed with hypertension before a stroke occurs.   That doesn’t mean that we shouldn’t try our best.

The bitter pill to swallow is that our best may not be good enough.  But, it could be better.   Your personal best may be to spend an extra ten minutes with a patient so your functionally illiterate patient can understand the education you provided.  An agency may adopt a policy where breaking even financially on poor and Black patients is acceptable and schedule a few more visits.  Case managers could supplement visits with regular phone calls.  Safety for nurses and patients may be enhanced by an inservice from local law enforcement.

The value of a life is constant throughout races and economic status.  As Malcomb Forbes once said, “You can easily judge the character of a man by how he treats those who can do nothing for him.”  But you may be surprised.  The people who appear to be able to do nothing for you often do the most.

NOTE:  This is an article about African Americans.  I have used the term ‘Black’ because that is what was found in the literature and it is easier to type.  No disrespect is intended.

Guess What Happened!

3D_Influenza_blue_no_key_full_med

Image of the Flu virus courtesy of the CDC.

Guess what happened this past weekend?  The flu season officially started.  Although most people don’t like the flu season, the advent of flu season is better news than the LSU homecoming game score.  Someone should invent a vaccine for the malaise that oozes out of Tiger Stadium and infects the entire state of Louisiana when LSU loses a game deliberately stacked in their favor.  Where is Les Miles when you need him?  I’m not even sure where Troy is.

Back to the flu.  Last year’s flu season certainly wasn’t the worst we’ve seen but an estimated 71,000 flu related hospitalizations were prevented because people received the flu shot.  Is your hospitalization rate high?  Lower it with the flu vaccine.  A full 2.5 Million MD visits were prevented because people received the flu shot.  That’s about equal to the population of the state of Oregon.

We know that Medicare doesn’t give away stuff for free so have you asked why there is no charge for the vaccine?  The total number of hospitalizations for the flu each year runs about 200,000.

And yet, in home health and hospice, our hands may be tied depending state specific pharmacy laws.  In Louisiana, you have to figure that if LSU can’t beat Troy at our homecoming game, we are likely worthless against a deadly virus that kills between 3,000 and 50,000 people each year depending on the severity of the flu season.   Because most states do not allow nurses to carry medications that are not labeled for individual patients, multi-use vials are not allowed to be carried by nurses just in case a patient is in the mood for a flu shot.  While getting an order is not difficult, many nurses are not comfortable with injecting someone with the vaccine without having an emergency kit available for a possible reaction and it is impractical and wasteful to carry around a patient specific emergency kit for every flu vaccination given since it won’t be used.

According to the World Health Organization, for every 500,000 vaccinations given, someone will go into anaphylaxis (a condition causing the inability to breathe kind of like the way Louisiana residents gasped for air after Troy beat LSU on Saturday Night).

There is also a small but significant risk of coming down with Guillain-Barre’ after the flu vaccine.  Although this is one of the more undesirable effects of the vaccine, many people don’t realize that the flu causes more cases of Guillain-Barre’ than the vaccine.  So, roll the dice.  Get no vaccine and hope you don’t get the flu or get the vaccine and have a tiny chance of contracting Guillain-Barre’.  Of course, if you or your patients opt to forego the flu vaccine from your fall schedule this year and wind up sick with the flu, your chances of coming down with a pesky paralytic illness will be greater than those who didn’t get a flu shot and those that did get a flu shot combined.

So, here’s what you do.

  1. First go to the CDC Flu page.  There you will find all kinds of teaching materials for both patients and staff in multiple languages designed for various education levels.
  2. Check on your state’s regulations about the flu vaccine.  If permitted to do so, get said permission in writing.
  3. If you can’t carry flu unlabeled flu vaccine (much like LSU can’t carry a football), use this nifty widget to find out where your patients can receive a vaccine. You can even put it on your website if you want.
  4. Coordinate with your patients and physicians to get orders for patients who are truly bedbound or live in rural areas so distant that a simple trip to the drug store is out of the question.
  5. Encourage everyone in the household to get vaccinated. Leave one of those cute flyers from the CDC website taped to the refrigerator along with the list of nearby flu shot providers to reach the maximum number of family members.
  6. You can also vaccinate other Medicare beneficiaries in the household if you get orders from their physicians. (Technically, Medicare doesn’t require an order but I highly recommend that you give nobody any medication without one; especially someone you haven’t fully assessed and are unaware of their history and physical).
  7. If your agency is going to vaccinate a lot of people, consider billing for the flu shot. I have no earthly idea of how this is done but Medicare has graciously published a little info sheet for people who know what they are doing.  Note that you can only bill for patients with Part B.

The truth is that no matter what you do, the fact that Troy beat LSU cannot be changed.  But imagine if you or your patients get the flu and are too sick to do anything that takes your mind off the greatest LSU humiliation in recent history.  A situation like that could be the end zone for countless Louisiana residents.

And if you see Les Miles, tell him to come back.

MedPac’s Report to Congress

What is MedPac and why should you care?

Before I answer that question, I will admit that for years I thought MedPac was a Political Action Committee – you know, those huge organizations that use political contributions to try to win favor from lawmakers.  I was wrong.  Oops.  Or maybe it was just a bad name for the committee.

MedPac is a committee created pursuant to the Balanced Budget Act of 1997.  They are tasked with presenting information and recommendations to congress each year on payment to providers from Medicare.  There are eleven commissioners with impressive titles and yet they seem to know very little about the home health industry and show very little interest in learning.  I bet they are boring cocktail party guests if this lack of curiosity is pervasive.  Just yesterday, they posted their March report which, as always, includes chapter about Home Health payments.

It is a long and boring document so please allow me to share with you the highlights.  Here’s the big one.

MedPac recommends another five percent reduction to your payment and the elimination of therapy as a contributor to payment as we know it.

To support their position, various factoids taken out of context are posited as evidence.  They note, for instance, that most beneficiaries can leave the home to go to the doctor and yet, Medicare does not provide any incentives for beneficiaries to receive services elsewhere.

Just to be clear, a trip to the physician for an elderly patient with congestive heart failure, COPD, a surgical wound, a recent CVA, etc. is necessary on occasion.  In terms of difficulty, getting a cat to the vet is probably easier (although to their credit, Medicare beneficiaries don’t howl).  It can take the better part of a morning to help the patient bathe and dress.  Getting into the car is like directing an elderly person through a Cirque du Soleil rehearsal and upon arrival at the doctor’s office you might find that helping them out of the car makes getting into the car seem like child’s play.  Of course, all of this must be repeated in reverse after the office visit and elderly people who are confined to the home are often eager to have a meal out somewhere since they’ve already endured the torture associated with automotive travel.  Everyone is exhausted after the outing but it is worth it.  The patient gets medical care and the family spends some time providing their loved one with a good meal and company.  Passing a good time is not always easy.  MedPac doesn’t quite get that.

Having said that, lives would be in danger if this was a twice weekly occurrence and not just the patient’s life.  Even if a family had the will to survive such an ordeal several times a month, where would they take a patient for medication and diet teaching?  Does MedPac believe it would be less expensive to send a patient to the ER for IV medications?  About the only alternative I can think of is a skilled nursing unit or rehab facility that costs more and deprives the patient of the comforts of their home.

Patients requiring therapy often do go to outpatient therapy as suggested by MedPac, upon discharge from home health once the patient is no longer homebound.   We should not have to be the ones to inform MedPac of how this works.

The report talks about a 2015 CMS review of home care services that revealed that almost 60 percent of claims were missing information that satisfied Medicare criteria.  The report does not address all in the information sent to their contractors that is lost so neither will I.  I could but I won’t.  What’s important is the time frame of the report which resulted in an expansion of Medical review and the Preclaims Review Process.  MedPac uses cost report data that doesn’t not include the added expense of being under scrutiny or having to participate in the PCR process.  There are no home health leprechauns who put together charts and ensure that all the right pieces are put together so that the chart can be sent to the Medicare contractor that requested it. Paid employees do this work.

Another thought that occurs to me unbidden, as I hate to be unkind, is that when 60 percent of claims are found to be lacking one or more elements of documentation that satisfies Medicare requirements, maybe the problem is with the reviewer.  Maybe there should be more education available to providers.  Hell, I’d be happy if there were a number I could call and ask a question.  (CGS is excepted from this last comment.  Lately, I’ve been calling them for questions even though most of my clients bill Palmetto GBA).

There is so much more in this report that illustrates with utter clarity how little insight MedPac has into our industry but the therapy issue really gets under my skin like scabies.  MedPac believes the increase in therapy is not justified in the very same report that notes that hospitalizations in home health patients has decreased from 28.8 percent down to 25.4 percent.

Another way of saying that is that an increase in therapy visits coincided with a decrease in hospitalizations.  Even I know that correlation does not equal causation but MedPac presents no hard numbers to demonstrate that the lower hospital rates are not related to increased therapy although they speculate a little.

So, MedPac wants home health to take another hit.  Bully for them.

Back to the original question:  What is MedPac and why you should care?  The first part of that question has been answered.  More info is on their website if you are still curious.  The second answer is that this information is prepared for the US congress.  Unless they hear other points of view, our industry will continue to die a slow death by strangulation.  Our state and national associations have lawyers and lobbyists who can construct arguments with greater legal authority than most of us and I have no doubt that they will.  But if I were a senator or a representative (fat chance of that ever happening), I would want to hear directly from the people affected by these proposed cuts.  So, take a few minutes and let your congressmen know how very myopic and well, stupid this report is and suggest they put it in the recycle bin.  There’s no point in killing trees, too.

Revised Conditions of Participation – Part 4

Two More Conditions of Participation

The next two conditions apply to the people who visit patients on behalf of your agency regardless of whether they are directly employed or contract personnel.

Skilled Professionals

Skilled professionals include nurses, therapists (Physical, Occupational and Speech) and Social workers.  The qualifications are expanded upon under another Condition of Participation, §484.115 Personnel qualifications.  So, this standard is as follows:

484.75 Condition of participation: Skilled professional services

Services are authorized, delivered, and supervised only by health care professionals who meet the appropriate qualifications.

Responsible for:

  • Ongoing interdisciplinary assessment of the patient;
  • Development and evaluation of the plan of care in partnership with the patient, representative (if any), and caregiver(s);
  • Providing services that are ordered by the physician as indicated in the plan of care;
  • Patient, caregiver, and family counseling;
  • Patient and caregiver education;
  • Preparing clinical notes;
  • Communication with all physicians involved in the plan of care and other health care practitioners (as appropriate) related to the current plan of care;
  • Participation in the HHA’s QAPI program; and
  • Participation in HHA-sponsored in-service training.

Supervision

  • Rehabilitative therapy services are provided under the supervision of an occupational therapist or physical therapist
  • Medical social services are provided under the supervision of a social worker

Action:

  • Ensure that all employees are aware of responsibilities to QA program.
  • Begin involving entire agency now.
  • Clarify care coordination roles for nursing and therapists
  • Review recent charts for evidence of communication, patient teaching and collaboration. If unable to identify these elements, revise policies and educate staff.
  • When the above elements are identified, share the documentation with staff as examples of what is expected.

484.80 Condition of participation: Home health aide services

The requirements for home health aide services are  extensive.  The first section reviews what is to be included for agencies that train their home health aides.  Most agencies I work with hire home health aides who have a certificate from a trade school or hospital, etc.  Since the training requirements and competency requirements are very similar, I made you a short list of all the required elements.  home-health-aide-training.

This section is for the rest of you that hire qualified home health aides.  Your responsibility is to assess competency and supervise these valuable employees.

As an aside, you won’t find anything about criminal history background checks here.  This does not mean you do not have to run a background check that meets your state’s standards.  My go to guy for over 15 years Ernie of EF Research.  He pretty much knows everything about background checks and can run them faster than the state police in most cases.   If you know of any other resources, please post in comments.

Back to home health aide competency which is to be assessed before an aide is assigned patients.

Competency must include:

  • Communication skills, including the ability to read, write, and verbally report clinical information to patients, representatives, and caregivers, as well as to other HHA staff.
  • Observation, reporting, and documentation of patient status and the care or service furnished.
  • Reading and recording temperature, pulse, and respiration.
  • Basic infection prevention and control procedures.
  • Basic elements of body functioning and changes in body function that must be reported to an aide’s supervisor.
  • Maintenance of a clean, safe, and healthy environment.
  • Recognizing emergencies and the knowledge of instituting emergency procedures and their application.
  • The physical, emotional, and developmental needs of and ways to work with the populations served by the HHA, including the need for respect for the patient, his or her privacy, and his or her property.
  • Appropriate and safe techniques in performing personal hygiene and grooming tasks that include –
    • Bed bath;
    • Sponge, tub, and shower bath;
    • Hair shampooing in sink, tub, and bed;
    • Nail and skin care;
    • Oral hygiene;
    • Toileting and elimination;
    • Safe transfer techniques and ambulation;
    • Normal range of motion and positioning;
    • Adequate nutrition and fluid intake;
    • Recognizing and reporting changes in skin condition; and
  • Any other task that the HHA may choose to have an aide perform as permitted under state law.

Underlined tasks must be performed by observation of the aide with a patient.  The remaining tasks may be observed directly or competency may be assessed through oral or written exam.

Supervision

If home health aide services are provided to a patient who is receiving skilled nursing or therapies, a registered nurse or other appropriate skilled professional makes a visit no less than every 14 days.  The supervision visit must be made by a skilled professional who is familiar with:

  • the patient,
  • the patient’s plan of care,
  • and the written patient care instructions

If an area of concern in aide services is noted by the supervising registered nurse or other appropriate skilled professional, then the supervising individual must make an on-site visit to the patient’s home in order to observe and assess the aide while he or she is performing care. (Present Supervisory Visit).

If the deficiency in aide services is verified during an on-site visit, then the agency must conduct, and the home health aide must complete a full competency evaluation.   That’s three things.  Here they are again.  I like lists.

  1. A deficiency is observed during a supervisory visit
  2. The Supervising nurse or other skilled professional will perform a present supervisory visit, and if a deficiency is observed;
  3. The aide’s competency is assessed again.

For agencies providing home health aide services paid for by Medicaid, (waived services), the aide’s competency may be abbreviated to include only those tasks that are specific to the patient.

Actions:

  • Verify competency now
  • Educate nurses and therapists regarding elements of competency defined by new CoPs.
  • Determine how your staff becomes familiar with the patient and commit it to policy.
  • Improve your hiring process to exclude candidates who do not have the dedication required to meet and exceed your standards.
  • Double up on education.  It will be less expensive to improve your home health aide services than investigating multiple complaints and your patients will appreciate excellent home health aide services as opposed to merely adequate.

None of this will be difficult for most agencies but when considering the patient rights condition which includes complaints together with the supervisory requirements in the home health aide services condition, a bad hire could be costly.  I’ve known agencies to skimp on competency because of a sudden need for a new aide.  This can’t happen anymore.  It shouldn’t have happened in the past.

Stay tuned.  The best is yet to come.

More Conditions of Participation

484.55 Condition of participation: Comprehensive assessment of patients.

Most agencies will not find it difficult to comply with the requirements in the Comprehensive Assessment because they are already assessing these areas.  The fact that ‘Cognitive Status’ which is already included in the OASIS data set and ‘Patient Goals’ are now mentioned in the Conditions of Participation may be an indicator of exactly how serious Medicare is about changing their focus to a patient centered approach to care and outcomes as opposed to the more punitive approach of hunting for agencies that disregard regulations.

The biggest change regarding the Initial Assessment that I see is that the Occupational Therapist is now able to complete the initial visit if OT is the only service ordered by the MD and if the need for OT establishes Medicare Eligibility.  Welcome to the world of Admits, OT’s.

Content of Comprehensive Assessment

  • Current health; functional and cognitive status
  • strengths, goals and care preferences
  • Continuing need for home care
  • Review of all medications (Identify potential adverse reactions, ineffective drug therapy, side effects, significant drug reactions, duplication and noncompliance with meds.
  • Patients primary caregiver and other available support
    • Willingness to provide care
    • Availability and schedules
    • Patients representative if any
  • Incorporation of OASIS data

Recertification visits are still done within the same time frame (days 56 through 60 of episode).  Resumption of care visits are done within 48 hours of the patient’s return to home OR on physician ordered ROC date.

Plan of Care

Patients are accepted for treatment on the reasonable expectation that the agency can meet medical, nursing, rehab and social needs in the home.  Care plan must specify the care and services to meet specific needs identified in the comprehensive assessment.

Plan of Care contents

  • All pertinent diagnoses
  • Mental, psychosocial and cognitive status
  • Types of services, supplies and equipment required
  • Frequency and duration of visits to be made
  • Prognosis
  • Rehab potential
  • Functional limitations
  • Activities permitted
  • Nutritional requirements
  • All Medications and Treatments
  • Safety Measures
  • Risk for Emergency dept visits and rehospitalizations
  • Measures to mitigate risk of above
  • Patient and caregiver education
  • Specific interventions and education
  • Measurable outcomes and goals mutually identified by the patient and agency
  • Advance directives
  • All orders

Each patient must receive a copy of their plan of care.

Additionally, each patient is to receive written instructions that include:

  • Visit schedule
  • Med list with names, dosages and any meds to be administered by agency
  • Any treatments including those administered by agency or persons acting on behalf of agency including therapy.
  • Any other pertinent instructions specific to the patient’s care needs
  • Name and contact information of the agency clinical manager.

Revision of POC

There is nothing new here but something has been removed.  There is no requirement that a 60 day summary be sent to the physician.  It shouldn’t be needed if agencies abide by the following.

  • The plan of care must be reviewed and revised by the physician responsible for the home health plan of care at least every 60 days .
  • Agency MUST promptly alert relevant physicians to any changes in the patient condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered.
  • Revised plan must reflect current information from updated OASIS and contain information about progress to goals.
  • Revisions must be communicated to the patient, representative (if any), caregiver and all physicians issuing orders for the plan of care.
  • Revisions related to discharge planning must be communicated with all of the above plus the patient’s primary care practitioner or other healthcare professional who be providing care for the patient in the community.

Conformance with MD Orders

  • Drugs, services and treatments are administered only upon the order of a physician.
  • Influenza and pneumococcal vaccines may be administered per agency policy developed in consultation with a physician, and after assessing for contraindications.

Actions:

  • Review the way your agency handles plans of care and ensure your process includes a mechanism for dissemination of information to all physicians writing orders for a patient.  Review or develop a vaccine policy that allows for administration of flu and pneumonia vaccines according to a well-written protocol developed in conjunction with a physician.
  • Most agencies will have to expand the collection of information related to caregivers and availability.
  • Begin now to audit admissions for the requirements set forth in the CoPs.
  • Begin reviewing admissions using a tool based on the new requirements.  admission-review-tool.pdf  Modify to fit the needs of your agency.
  • Educate your staff.

More Later.  And to think, we haven’t even looked at Quality Assurance, yet.