Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare
The OIG posted its study of Home Health Agencies and their response to the COVID-19 pandemic on October 18, 2022.
Home health agencies (HHAs) developed strategies to respond to challenges during the COVID-19 pandemic, including providing new incentives to maintain staff and seeking alternative sources of personal protective equipment. HHAs have also benefited from support from the Centers for Medicare & Medicaid Services (CMS), such as regulatory flexibilities and expanded telehealth allowances, but staffing challenges persist. In light of the expanded use of telehealth, more information is needed to determine its future use across different home health services.
What OIG Found:
Like all health care providers, HHAs have experienced multiple challenges to providing care during the COVID-19 pandemic. HHAs have continued to experience longstanding staffing challenges as well as new ones resulting from the pandemic, such as maintaining staffing despite quarantine and isolation protocols. These staffing challenges persist for many HHAs despite efforts to address them. In addition, HHAs faced numerous and widespread infection control challenges, including accessing personal protective equipment (PPE) to limit exposure and spread, but these have mostly eased since early in the pandemic.
HHAs’ own strategies to respond to the pandemic included offering paid leave to retain staff and finding PPE from nontraditional sources. HHAs have also benefited from government support—including regulatory flexibilities instituted in response to the declaration of a public health emergency—and this support has mitigated some staffing challenges. For example, by the Federal government’s allowing new types of providers to certify and order home health services and complete certain patient assessments, HHAs could more efficiently provide care. Telehealth flexibilities under the public health emergency have also helped HHAs provide care while reducing COVID-19 exposure and dealing with staffing shortages. However, HHAs’ challenges with telehealth raise questions about its future role in home health care, and—because of limited reporting requirements—CMS has limited insight into HHAs’ telehealth use. Finally, the emergency preparedness plans required by CMS guided HHAs’ responses to the pandemic but fell short of fully addressing a global emergency such as COVID-19.
What OIG Recommends:
CMS has an opportunity to assess how to best help HHAs prepare for and respond to future emergencies, as well as to evaluate how changes to the home health landscape can better serve patients. To that end, we recommend that CMS evaluate how HHAs are using telehealth-specifically, the types of services provided via telehealth and the characteristics of patients who benefit from these services. We also recommend that CMS-to inform decision-making-evaluate how the regulatory flexibilities it has offered in response to the COVID-19 public health emergency affect the quality of home health care. Finally, we recommend that CMS-in collaboration with the Administration for Strategic Preparedness and Response’s (ASPR’s) Technical Resources, Assistance Center, and Information Exchange (TRACIE)-apply lessons learned from the COVID-19 pandemic to update and/or develop emergency preparedness trainings and materials for HHAs on responding to infectious disease outbreaks. CMS concurred with all three recommendations.
I cite these 3 exhibits that illustrate staffing challenges during the PHE:
I cite this exhibit that illustrates the OIG finding that most HHAs (73 percent) used telehealth during the pandemic and used it to conduct visits, share information, and facilitate interactions with outside providers.
The 61-page report is an interesting read. I encourage you to share the study with your team and colleagues.