The Public Health Emergency’s End Will Mark ‘Significant’ Change For Home Health Providers

Now that the public health emergency (PHE) is ending, home health stakeholders are taking stock of what ripple effects will impact the industry most.

The Trump Administration first declared the PHE in March of 2020, retroactive to Jan. 27, 2020. In January, the Biden administration announced that the PHE would end on May 11.

Broadly, the PHE ushered in a number of different waivers and flexibilities meant to lessen the disruption the pandemic had on providers. In some cases, those changes had become the norm. Until now.

Advertisement

PHE waivers and flexibilities come to an end

The PHE put the requirement that a nurse has to conduct onsite visits every two weeks, including the requirements for aide supervision, on hold.

Sherry Teague — co-owner and co-founder of consulting firm Kornetti & Krafft Health Care Solutions — believes that this will be a blow to providers.

“It’s going to be a significant change for agencies,” she told Home Health Care News.

Advertisement

As part of the PHE, the Centers for Medicare & Medicaid Services (CMS) also provided relief on timelines to complete OASIS comprehensive assessments and submission.

Also, therapy staff will no longer be able to complete the initial or comprehensive assessment for patients where therapy was not the qualifying service, even if they are part of the care plan.

“Both of these changes will impact staffing, both who can go out to start the initial and comprehensive as well as getting it done in the new timelines,” Katy Barnett, director of home care and hospice operations and policy at LeadingAge, told HHCN.

Barnett noted that some of LeadingAge’s members have expressed concern about the loss of the therapy assessment waiver, which opened the door for patients to receive services faster.

Embedded in all of these concerns is an overarching one: working with a staff that was built after the PHE was already established.

“A large part of our workforce was hired during the public health emergency and has been functioning under waivers, so it’s all they’ve known,” Joanna Horst, chief clinical officer of home health and hospice at Bayada Home Health Care, told HHCN in an email. “As an organization, we must account for the time and resources to educate or re-educate our leaders and staff on our standards and policies without waivers.”

A new era

In some ways, the PHE introduced a new era for home health providers. Many of the new waivers and flexibilities gave them new ways to stretch their resources and increase access to care.

“The ability to better utilize staff to meet new patient needs — for instance, an occupational therapist or physical therapist starting the assessment – has been invaluable during this nurse staffing crisis,” Barnett said.

Another major PHE gain was mid-level clinicians now being able to certify home health in most states, according to Teague.

“This was also part of the CARES Act, so that’s permanent,” she said. “It’s not going away with the end of the PHE. This is a big boon for communication between the agencies and the [clinicians].”

Many providers are considering this era a major step forward for telehealth as part of home health care.

“Many of our clients are homebound, and physically getting back to a provider can be extremely difficult,” Horst said. “Telehealth support is an invaluable resource to our partners — physicians, nurse practitioners and PAs.”

This waiver was extended until Dec. 31, 2024, but Barnett pointed out that continued advocacy will be needed for it to remain in place.

In the months, weeks and days leading up to the PHE’s end, providers have been preparing.

Bayada developed a comprehensive rollback communication and education tool and distributed it to the company’s offices in advance to prepare, according to Horst.

Barnett believes that providers should be talking to their staff about what’s changing.

“Prepare them so they can get those assessments done in 5 calendar days,” she said. “Start reviewing your QAPI and make sure it’s looking beyond infection control and adverse events, which was a waiver many used under the PHE. Also make sure your discharge staff know that you’re going to have to start providing more information to patients and families about other post-acute providers.”

It is also important for the staff at home health agencies to understand that infection control expectations around COVID are not going away. Leaders should also communicate updates around the federal vaccine mandate, experts suggest.

Ultimately, the biggest preparation will be a much-needed mind shift.
“I’m hearing that people have gotten used to the rules,” Teague said. “They’ve gotten used to the last three years of how things are supposed to go. They’ve gotten used to business as usual, and now they’re having to switch back to pre-pandemic.”

Companies featured in this article:

, ,