Home Health Agencies: CMS Flexibilities to Fight COVID-19 

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

CMS has provided this 13-page document (same title as this blog) dated February 1, 2023 to announce preparations for after the PHE ends.  This document is specifically for Home Health Agencies.

At the beginning of the COVID-19 Public Health Emergency (PHE), CMS used emergency waiver authorities and various regulatory authorities to enable flexibilities so providers could rapidly respond to people impacted by COVID-19. CMS has developed a cross-cutting initiative to use a comprehensive, streamlined approach to reestablish certain health and safety standards and other financial and program requirements at the eventual end of the COVID-19 public health emergency.

This CMS cross-cutting initiative aims to evaluate CMS-issued PHE blanket waivers and flexibilities to prepare the health care system for operation after the PHE. This review is being done in three concurrent phases:

1. CMS is assessing the need for continuing certain blanket waivers based on the current phase of the PHE. Since the beginning of the PHE, CMS has both added and terminated flexibilities and waivers as needed. In doing so, CMS considered the impacts on communities — including underserved communities — and the potential barriers and opportunities that the flexibilities may address.

2. CMS is assessing which flexibilities would be most useful in a future PHE, such as natural and man-made disasters and other emergencies, to ensure a rapid response to future emergencies, both locally and nationally, or to address the unique needs of communities that may experience barriers to accessing health care.

3. CMS is continuing to collaborate with federal partners and the health care industry to ensure that the health care system is holistically prepared for addressing future emergencies.

As CMS identifies barriers and opportunities for improvement, the needs of each person and community served will be considered and assessed with a health equity lens to ensure our analysis, stakeholder engagement, and policy decisions account for health equity impacts on members of underserved communities and health care professionals disproportionately serving these communities.

This document addresses:

  • COVID-19 Vaccines
  • Payment After the End of the PHE
  • Additional Payment for Administering the Vaccine in the Patient’s Home
  • Additional Payment for Administering the Vaccine in the Patient’s Home After the End of the PHE
  • COVID-19 Monoclonal Antibodies
  • COVID-19 VEKLURY™ (remdesivir) in the Outpatient Setting
  • Medicare Telehealth and Telecommunications Technology
  • Reducing Administrative Burden
  • Medicare Appeals in Traditional Medicare, Medicare Advantage (MA) and Part D
  • Cost Reporting
  • COVID-19 Diagnostic Testing
  • Workforce
  • Additional Guidance

This is a must-read guidance to be shared with your team and colleagues, so you’re prepared for the end of the PHE!  There’s a LOT of information in this document.