Today, this article will look at little different than out typical articles. We all know the costs of losing employees and trying to hire and train new ones. It is exhausting and expensive. So, we think about our wages and benefit packages all the time. What can we do differently that makes people stay? We can’t change the job and we don’t want to keep people that don’t like the work itself. So, how do we acknowledge employees in a way that is valuable to them and that our businesses can afford to do? 5 Things To Consider About Employee Recognition At Your Christmas Party: 1. Years of Service: These can be based on milestone work anniversaries (5, 10, 15 yrs, etc.). If a person has been at your agency 11 years, you pull them up and acknowledge them in the group of employees who have been there at least 10 years up until the time they hit the 15 years landmark. This way longevity is recognized yearly. 2. Special Employee awards: Now, this may be difficult if your staff is very small, but acknowledge the employee who has gone the extra mile in the job they do. Tell the story. The employee needs to know when the employer is proud of the work that has been done. Consider a plaque or certificate. Don’t minimize the value of the employee having them to display. 3. Acknowledge all employees in the mix: Because we are a clinical industry, the administrative staff is often overlooked on day-to-day operations. Ultimately, don’t miss the chance to acknowledge the employee who was able to catch billing errors or collect on a large account. Staff doesn’t like to hear about money, but those types of collections keep Christmas bonuses in place! So, make sure the other staff knows the accomplishments of the finance department or the office manager that every caller loves to speak to. Don't ever forget the IT staff that is on call more than any clinical person in your agency! 4. Letters from the administration: Add a personal note to your staff either collectively or individually depending on the size of your agency. If you are larger, there are employees you don’t often see or get to talk to on a regular basis, so take the time so send a note with that Christmas bonus. 5. Consider the Christmas bonus: Listen, some of you can afford to do substantial monetary bonuses and that is fantastic. However, if you are not in that position, consider something in its place. Maybe small gas cards go with the letter from administration. With the cost of groceries, consider something that helps with the costs of daily living for employees. Big box gift cards in your area will always be used. You may do a lot of these things on a yearly basis to employees. All this being said, it doesn’t mean there aren’t reasons for acknowledgement throughout the year. However, your annual Christmas party is a good way to do it collectively. Between your annual party, write the individual cards to employees when you hear a patient interaction worthy of praise. Or, maybe you buy a gas card for the employee who has picked up extra shifts and always shows up on time. Ultimately, employees will feel valued. You will not regret the time, effort, and energy put into these efforts. Merry Christmas! If you want help with recruitment and retention strategies for your agency, please call Kenyon Homecare Consulting at 206-721-5091 or contact us online today.

When you think in practical terms, what does your ICD 10 coding mean to the clinicians in your agency? It probably isn't as important as you would like. Realistically, your nursing staff cares about hands on patient care. If you want the code itself to be more meaningful, then you need to attach the concepts of patient care to the ICD coding. You may think the code itself goes hand-in-hand with the care, but this is not always true. As a clinician, there are concepts within the nursing care plan that are automatic and some that are instinctual based upon the body system causing the need for care. It's a given that medication, diet, and disease process teaching are going to be in the care plan (or should be). When you get to disease process, our experience shows the clinician doesn't always run deep into the specifics of the disease when it could lead to valuable interventions being included in care. For example, when clinicians do a care plan related to cardiac disease, are the interventions very broad to include all things related to any type of cardiac disease? If you have a patient with right sided heart failure versus left sided heart failure, how many nurses would assess the patient differently? Would your nurses change the frame of mind to look for distended neck veins or anorexia and nausea if the patient had right sided failure? Would they be in the head space of considering whether the patient's appetite changes are more about just having been in the hospital than about potential venous stasis in the abdomen? The point is that although there are certain interventions that would be the same regardless the type of heart failure, picking up on different symptoms and critically thinking through the cause is often missing in the hustle and bustle of the day-to-day. This is not a judgment on the capabilities of the nurses but more about how our nurses are trained to consider care planning and assessment. We have people for ICD 10 coding now. Most nurses are not in the ICD coding manual looking up their own codes anymore because of the specificity that wasn't the same 25 years ago. So, the nurses go out with an H&P from the hospital or doctors office and develop a care plan. It isn't necessarily with the coding in mind. So, we need to get back to basics when it comes to coding and clinical care. We need to train out staff to look harder at the coding. Our coding departments need to have open communication with clinicians and understand the concepts of care planning to understand if things are missing in the care plans. What about your clinical manager's role? Are these things considered when reviewing care plans? What about your record review process? Are your ICD 10 coders nurses that understand care planning and is it part of the coding process to review the care plan? These are things to consider when you look at your clinical practice as well as your coding solution. At Kenyon Homecare Consulting , we have a comprehensive ICD 10 coding department that can provide education to clinicians, accurate ICD 10 coding, care plan and Oasis review. Call us at 206-721-5091 or contact us online to see if we can help you merge the code with the clinical practice in a way to improve your outcomes and your bottom line. We will offer 5 free recodes to any agency that would like us to check the efficacy of their current coding system or talk about becoming your coding solution.

When your survey is done, is there a collective sigh of relief at your agency? Is it because it was successful and you can continue as usual? Is it because you have so much to do and now you don’t have to be at the surveyor’s beck and call? Or, maybe your policy and procedure manual just got annihilated and you are going to have a huge plan of correction with an overhaul of your manual? The latter means we need to talk about fixing your manual and what way to do it. Do I Buy An Online Manual Or Fix Mine? Well, that truly depends on you and your business. If you only have a policy or two that gets cited, updating your manual may be a quick fix for your agency. This is normally the case if someone is routinely updating it and the manual is used to run your business. Ultimately, your agency needs to keep the document a living breathing manual or it will not serve its purpose. If your policy and procedure manual is not typically updated other than for survey, then you need to consider buying a manual. Your rule of thumb should be if your agency has not updated the manual within the last 3 years, you should consider purchasing a new one. There are many benefits to purchasing on online manual: Customization: Pick a manual that allows you to fully customize policies to fit your operations. You should not buy a manual that doesn’t provide this option. You need to be able to prove to the surveyor how your agency complies with the regulation. If the policy is written a certain way and you don’t change it to meet how you operate, you will still be cited. Forms/ Documents: Certain online manuals also provide forms that coincide with the policies. This makes it easy for you to implement changes because forms are already generated. There is no reason to reinvent the wheel by making your own. Most of these forms allow you to place your logo and any specific personalization within the document. · State Rules: Several vendors have incorporated specific state rules into manuals. For instance, Kenyon Homecare Consulting offers skilled, non-skilled and hospice manuals as well as ones that have incorporated California and Washington state rules. This eliminates the individual business having to go back in and add state rules to the manual. Consulting Services: Pick a vendor that also has consulting available should you need assistance in customizing your manual to meet your state rules or specific program rules. This makes the process easier especially if you are new to the policy writing and editing. Up-to-date: This is the biggest advantage. These manuals have been updated to include the rules you need. We have seen so many agencies over the last several years not keep up with COP changes and it cost them at survey and with compliance. These manuals are routinely updated with changes so when you purchase your manual it will have the current federal regulations. Ultimately, you have to decide whether it makes sense to rewrite your manual with updates or purchase one that is currently up-to-date. At Kenyon Homecare Consulting , we offer customizable manuals for all service lines, accreditation, and incorporated with certain state rules. Please call at 206-721-5091 or contact us online before purchasing your manual so we can ensure you have chosen the correct one to meet your needs. We also offer consulting services to help incorporate your state rules should you need assistance.

By Jed Hammel: I started my career in the 1990s working for GE, a company led by one of the greatest business leaders ever to have lived, Jack Welch. Jack left GE in 2000 (and so did I - haha). One of his great quotes was "What you measure is what you get." In that theme we've been exploring a lot about measurements. When we first started building home care software it was all about transactions: Onboarding a client, scheduling, clocking in and out, billing, etc. This is the work we do to run the business, but what do we do to grow our business - measure! Home Care Growth Measurements - The Most Important Ones! Our customers told us that the most important measures are as follows: Growth: Hours per week and revenue are the key ones. Note that you might think that number of clients should be on that list as well, but remember that an agency with 5 24x7 clients has more revenue than an agency with 80 10-hour per week clients. Gross-Margin: One of the most troubling statistics in the Home Care Pulse Home Care Survey has shown that the profit margins of home care agencies have been dropping in the past two years. It's not surprising because there's increased demand for home care and there have been fewer available caregivers so the amounts we're paying caregivers have gone up. To combat this, agencies need to charge more and look hard at the cases where the caregiver pay or overtime is eating up all the revenue. Operations: Most of our agencies use electronic clock-ins and clock-outs. On the Medicaid side this is called Electronic Visit Verification (EVV) but essentially all of our clients (including agencies who mostly support private pay and long-term care insurance) are doing it to have real time status and to streamline billing and payroll. Billing for All Available Hours: One metric that some but not all agencies track is whether they're delivering and and getting paid for all of their available hours. Again jumping to the Medicaid side, most Medicaid agreements come with a specifically authorized number of hours (or units) per week or month and the way Medicaid works is that you are encouraged to deliver all the hours be penalized if you go over. Most of you private duty folks are probably counting your blessings that you don't have to deal with that, but a nice thing about it is that it establishes a target number of hours for the agency and let's you know that you're getting it done. What Metrics are Recommended by Home Care Growth Champs like HomeCare Evolution by Steve the Hurricane? Coincidentally, we recently we were joined by Melissa Bagley, one of the expert coaches from Home Care Evolution, on our Home Care Heroes Podcast. You can listen to her episode here: https://podcasts.apple.com/us/podcast/adapting-your-home-care-agency-for-the-future-with/id1548408985?i=1000551422539 Two follow-up thoughts: If there's no way you're going to listen to the podcast, Melissa's recommendations are totally in line with the list above :) If you think Podcasts aren't your thing, you might want to reconsider for the reasons that A) Home Care leaders spend a good amount of time in the car visiting prospects, referral partners and clients, and B) Rather than listening to news (which is mostly bad news), podcasts are educational and uplifting. Best Practices: Dashboards should summarize information so you can get an immediate sense of how things are going. Your dashboard should answer the question "Are we delivering and getting paid for all the services we've been asked to deliver." It's a powerful end to end measure of operational efficiency. Best Practice: Summaries are great, but you need drill down to see where the problems are. Referring to the same dashboard, note that it's great to see a summary, but you also need to be able to drill down to see where the issues lie. Best Practice: Graphs are Nice but Managers generally prefer numbers. A good view of caregiver compliance lets management know at a glance how their caregivers are doing with clock-ins and clock-outs. In this case the pie charts are very useful. By contrast, managers generally prefer numbers and pride themselves on knowing their numbers off the top of their head. Overall business owners can usually tell you their number of clients and weekly hours, whereas recruiters can tell you their number of applicants, number of hires, percentage of candidates attending interviews and percentage hired. Here's a pure numbers dashboard with week by week data. Best Practice: Manage by week, but be prepared to provide data by month, quarter, and other ways. There are weekly summaries of growth with week over week comparisons, but monthly results should be accessible with the touch or a button. Similarly, you want to be able to look at pretty much any time period, but we recommend not looking at less than a week's worth of data because most agencies have fewer visits on the weekends. Takeaways: My church pastor once told me that no matter what sermon they were writing, the initial outline was "What?, So What? and Now What?" So, what should you do after reading this article. Here it is: Identify your key metrics - if you're not sure where to start go with weekly clients, weekly hours of care, gross margin, and recruiting Find an easy way to see the data - hopefully via dashboards with drill down as explained above (if you don't have this, we'd be happy to help - here's how to contact Ankota). Assign leaders to own and drive each of your key metrics Review them regularly, ideally week by week If you have any questions about dashboards or how Ankota's home care management software can help your business, please click below to contact us ! Ankota provides software to improve the delivery of care outside the hospital, focusing on efficiency and care coordination. Ankota's primary focus is on Care Transitions for Readmission avoidance and on management of Private Duty non-medical home care. To learn more, please visit www.ankota.com or contact us . Kenyon Homecare Consulting can help you with all of your agency's needs. Whether you need assistance with your start-up, recruitment and retention, clinical or operational issues, regulatory compliance, or financial concerns, we can help. Call us today at 206-721-5091 or contact us online to see how we can help you reach your goals Kenyon Homecare Consulting reposted this article with permission of Jed Hammel who authored it and originally posted it to the Ankota Blog. 

By Stephen Tweed As the home care caregiver shortage continues, we recognize that there is no short-term fix. If you want to be successful in home care over a long period of time, you will need to develop a long term strategic initiative to attract and retain the caregivers you need. That means working diligently to create a great place to work. Crafting Your Company Culture: Creating a great place to work for caregivers means crafting a company culture that is in alignment with the needs and wants of your best caregivers. The most recent Best Caregiver Study from Leading Home Care and the Home Care CEO Forum showed that the most reliable workers in home care want: To do meaningful work To feel valued and respected by their clients, their supervisors, and company owners To have a flexible schedule To receive the proper education and training to do their work To feel fairly paid We define company culture as … “The way we do things around here.” Your culture is influenced by four factors; the leadership style of the CEO, the core values that guide your decisions and actions, the behavior you expect, and the behavior you permit. Building a company culture that will enable you to systematically find and keep the caregivers you need is a long-term commitment. Seven Steps To Crafting Your Company Culture: Crafting your culture is not easy, but there is a system that works. After studying dozens of companies that have crafted amazing cultures, and after interviewing CEOs of these companies, we have developed seven specific steps that are necessary to build a strong culture over the long haul: Define your Core Values Define the behaviors you expect for each Core Value Communicate your values and expected behaviors Train your leaders to Live Your Values Engage your Caregivers Promote Your Culture Reinforce Your Culture After leading this process for a number of home care companies, we’ve found that this seven step process takes at least a year to get through, and you are never done. The largest, privately owned home care company in the world has spent over 40 years working on their culture, and they are not done yet. The good news is, you can start today. Where To Start: The place to begin this process is defining your core values. When we lead this process of crafting your culture, we begin by brainstorming a list of values that members of the leadership team believe are important. Then we discuss each value, and define its meaning. We talk about what it means to live this value. Then, we narrow the list of values down to three. Why three values? Because people can’t remember more than four. If you have seven core values, and people can’t remember that last four then why have them? Pick the three that are most important and that your team members resonate with. Begin there. Top Tier Home Care Companies Are Working on Their Company Culture: As you know by know, through the Home Care CEO Forum and our Home Care Mastermind Groups , we work with companies in the very top tier of our industry. One of the common characteristics of our Top 5% Mastermind Group and our Top 7% Mastermind Group is that they are all working on crafting their company culture. They are working through the steps in this process in varying degrees. The fastest growing companies in these groups have built on their company culture to develop systems to recruit and retain caregivers. We’ve learned that you can only grow your home care company when you are able to attract and retain high quality caregivers, and crafting your company culture is part of that process. This article is being re-published with permission of the writer, Steven Tweed: Stephen Tweed, CSP, is an internationally known health care and business strategist, award winning professional speaker, and published author. He is the CEO of Leading Home Care… a Tweed Jeffries company and the Founder of The Home Care CEO Forum® and Caregiver Quality Assurance®. If you need assistance in your recruitment and retention efforts as well as looking at company culture, call Kenyon Homecare Consulting at 206-721-5091 or contact us online to see how we can help.

As a home care agency, you work so hard for clients. Your goal is to get the referral, provide the requested care, and then have a satisfied customer for years, right? Realistically, you normally spend more time on those who are not satisfied than the ones who are. If you are at wit's end, then you need to consider if it is time for the client to go somewhere else. Ultimately, it may be the best thing for your agency as well as the client. Reasons To Discharge A Client For Cause: Abuse of Caregivers: We have all had these clients. There is certainly a difference between the client who can be grumpy at times versus those clients that have caused your agency to lose good staff. Now your abusive client has caused you staffing issues across the board because caregivers resigned. There is no question that we cannot afford to lose good staff because they are treated poorly in client homes. Caregivers do not have to endure physical or verbal/ emotional abuse and agencies should not tolerate it. Client Needs do not fit agency expertise: If you determine the client has needs your staff does not have the skill set to provide, don't take the client. If you already have, then work with the client to find an agency able to provide the services that meet their. There is nothing wrong with communicating to your client that your specific specialty is different and that the client would be better served elsewhere. You do everything as asked, but it is never enough: All of you are currently picturing a particular client, aren't you? These individuals take up a ton of staff time without a true resolution to "problems". As soon as you fix one thing, it is something else. Ultimately, you have to ask yourself if you actually lose dollars by continuing to serve the client. You may have a lot of time invested versus the reimbursement you receive. Plus, you have to ask what kind of complaining this individual does in the community and whether servicing them hurts your business. Accusations against staff: Of course, any accusation against a caregiver needs investigated. In working with agencies, we have seen those clients who accuse multiple caregivers of the same infraction such as theft of medication or items of value. These same caregivers may be in many homes with never a complaint from anyone. One wrong accusation throughout the communities you serve can hurt your businesses. Expect Discounted Services: We have found that agencies offering discounts for services often have the clients who are never satisfied. If the client has gotten discounts related to complaints, then the client is potentially incentivized to complain. We understand the client may have financial concerns, but discounting your services minimizes your value. We understand your agency wants to keep as many current clients as possible, but not all clients help you build your business, retain employees, and have a positive profit margin. For these clients, there may be an agency that is a better fit or the client may need to have different and realistic expectations from the caregivers in the agency. At Kenyon Homecare Consulting , we help agencies achieve clinical, operational, and financial goals while providing high quality care. Call us today at 206-721-5091 or contact us online to see how we can help you get there.

For those of you who have been in home health for decades, the idea of competition between agencies revolved around how to get market share. You did marketing, developed relationships, maintained visibility in your communities and gave good care. With the nationwide expansion of Value Based Purchasing, competition has a whole new meaning to our industry. Let's look into the expansion. CMS began the original VBP project in 9 states on January 1st, 2016. It had 3 basic reasons listed for the project: Provide incentives for better quality care with greater efficiency; Study new potential quality and efficiency measures for appropriateness in the home health setting; and Enhance the current public reporting process. The goal was to show that quality scores could improve while there was a potential for significant savings to the Medicare program in dollars. The program showed that VBP did just that. CMS reports savings of $141 million annually with improvement of quality scores by 4.6% in those states originally involved. By this, it should be no surprise to our industry that CMS announced a nationwide expansion. CMS started the pre-implementation this year and has offered education to agencies to prepare for the full implementation on January 1, 2023. Agencies will see that payment rates will change beginning in 2025 based upon the performance numbers in 2023. You can register for the next scheduled CMS training entitled Navigating Performance Feedback Reports: Interim Performance Report (IPR) and Annual Performance Report (APR) which is scheduled for August 25th at 2pm ET. CMS also has many of the pervious recordings of trainings available for you here , so you can utilize the education and sign up for the listserv associated with Home Health Value Based Purchasing. The expanded Home Health Value Based Purchasing Model is set to base reimbursement on your performance in relation to other agencies like yours. It will look at certain quality measures each calendar year. Your OASIS, HHCAHPS surveys, and designated claims measures will calculate performance. An agency can expect between a -5% to 5% change in Medicare fee for service payments. So, what all this means for your agency is that you are not just competing for market share but for maximum reimbursement too. Agencies that do not perform will be hit for another loss to overall dollars. This could mean a transition of agencies no longer looking to provide Medicare services. It will be anticipated that certain agencies will not do well in the HHVBP model and not survive. The good news is that agencies focused on quality measures and patient satisfaction will thrive in HHVBP. Agencies need to keep the focus on Oasis accuracy, acute care hospitalization, and ER visits without hospitalization. Should you need consulting for your agency, Kenyon Homecare Consulting has senior level consultants with comprehensive knowledge and experience within the industry to help you navigate your clinical, operational, and financial needs. Call us today at 206-721-5091 or contact us online to see how we can help you succeed!

How many nights are you awake trying to figure out the recruitment and retention puzzle? You changed your benefit package, tried sign-on bonuses, raised salaries and still employees leave. Are you completely frustrated facing Value-Based Purchasing (VBP) and more budget cuts? Are you feeling burned out as an owner and/or administrator? Maybe it is time to take a look at you and where you are in taking care of the person responsible for everyone else. What's Going On With You? On a scale of 1-10, how engaged are you in your agency? Compare today to a year ago, 5 years ago and 10 years ago. What is the difference? Have you moved agencies more than once in that timeframe? The thought process is that we are there to take care of everyone else as well as the agency itself. That’s what we are paid to do, right? Well, yes and no. If you are at wit’s end, then how can you possibly be effective to to keep your employees engaged? That isn’t a judgment, but a legitimate moment to step back and ask who is taking care of you? If you have a very engaged board of directors, then you may have someone actively working on your recruitment and retention. If you don’t, then you need to recognize your own needs to make sure you are as effective as possible for the long haul. Do you have employees with an “A” scorecard who now consistently perform at a “C” level? Ask yourself what has changed? If they are coming into the same job and same conditions, same leadership etc., then something else is happening. Normally, we take the time and ask. We learn of things that may not have anything to do with the job that still affect it. It is usually situational and short term. These are things as administrators we work through with employees. What about your situation? My team are called into agencies where the leadership is frustrated whether it is financial or clinical or both. Agencies aren’t calling a consultant if everything is going well. You try to do everything not to pile more responsibility on everyone else often at your own expense. Have you evaluated your own breaking point? Who's Looking Into Your Recruitment And Retention? This is the big question, right? And just like employees, it may not be about the money. There may not be enough money for you to miss another child’s ballgame or family get together. So, what do you do to find the balance? Disconnect when you aren’t at work: This is the biggest “easier said than done” statement of them all. However, it is the most important. Ask yourself what happens to your agency if you don’t check your phone and email for the next 8 hours? Do you fail your agency if you don’t answer every email that comes through during the evening? How many times are you interrupted by things that could wait until the next morning? Here’s the tougher question: How much of it do you do to yourself? Have limits as to what you jump and run to do: You will not regret time spent with family, but you may regret vacation time talking with the office unnecessarily. Disconnect and develop reasonable boundaries so you don’t end up resenting going to work in the morning. Maybe you need additional vacation time: Let’s face it, the job isn’t the same as it was 5, 10, or 20 years ago. If you sit at the same vacation time you did 10 years ago, maybe it is time for more. Maybe the ability to disconnect hinges on the ability to truly get away from your physical location. Go somewhere with a different time zone. It doesn’t mean you aren’t available to employees, it just means they may be more willing to problem solve before calling if it is 4 AM your time. Get the right person to cover in your absence: We see a lot of agencies where the administrator and the back-up work well together. If your number 2 in charge doesn’t have autonomy and confidence to make decisions independently, then you don’t have a good number 2. Your back-up administrator needs to be confident to make what decisions are within his or her wheelhouse. If you go away for a week and get called several times, then you need to work with those in charge in your absence. There are certainly times where contact is necessary, but it needs to be the exception and not the rule. Successful recruitment and retention strategies for your agency have to consider you in the process too. What do you do to change your focus: I have to admit that this one was a tough one for me. How many times do you find yourself engaged in something else and realize you are right back to work in your mind? It is one thing to disconnect from something physical like your phone or your laptop, but a whole different story when it comes to your brain. Find what works for you. Podcasts (that have nothing to do with work), guided meditation, exercise, music, and time with friends/family all take you actively focusing on something else. Learning to keep your mind focused on something other than your business takes time. Everything Starts With Operations: You can know the regulations, have a great policy manual, maintain optimal recruitment and retention and onboarding , and yet still struggle. Being able to put the pieces together for operational efficiency and excellence is a different issue and skill set. So, understand your limitations and get the people around you that have the talents to complete the things you struggle to do well. We see it with employees everyday. Employees gravitate to the tasks they are good and thrive doing, so why would you be any different? You can have the best plan but need to have people around you that can help with the execution of it. At Peek Consulting , we work with homecare, home health, and hospice agencies who are looking for clinical, financial, and operational solutions for their agencies. This article is being republished with the permission of the writer, Shelly Barrett. Call Kenyon Homecare Consulting To Help With All Your Consulting Needs: If you need assistance with your homecare. home health or hospice agency or are looking to start and agency, Kenyon Homecare Consulting can help. Please call us today at 206-721-5091 or contact us online to see how we can make things easier for you! We have a comprehensive line of products and services to help you with all your need.

If you are members of the National Association for Home Care and Hospice or your respective state associations, then you may have already heard of the "Organization Deactivation Project 2022". If not, then your agency may be at risk if you haven't been servicing Medicare patients in the last year. Many states without licensure require agencies to be Medicare certified in order to meet state requirements for providing services to Medicaid and other non-Medicare payers. So, Medicare certification was a necessity and servicing Medicare patients was not necessarily your target for market share. It appears some agencies have already received letters from their Medicare Administrative Contractor (MAC) if they have not submitted Medicare claims in the past 12-13 months. Ultimately, those organizations in business to serve only Medicaid will want to consider marketing for some Medicare patients. Now, an agency that never plans to bill Medicare may not see an issue with deactivation of Medicare billing privileges. It becomes an issue if CMS wants to potentially revoke enrollment in the Medicare system which would negatively impact those states that have no choice but to be Medicare certified. An agency would then potentially need to submit a new 855 and start the enrollment process for Medicare all over again to bill for services. This would be costly for providers who would be going through additional survey and providing care for free during the interim. Ultimately, this may a be hard push from CMS for states without licensure to put it in place. From the federal level, you can see how this would make sense. It makes the states wholly responsible for those Medicare certified agencies billing for only for Medicaid and non-Medicare payers within the state. If CMS is looking into this, then agencies servicing only Medicaid and Medicaid waivers need to look closely at their patients. Are your dually-eligible patient qualifying for the Medicare home health benefit at different times but not being discharged from a Medicaid plan of care? Now, we have no confirmation that this is something CMS is looking at, but it could potentially show the states that Medicaid dollars are going to patients who qualify for Medicare services. At Kenyon Homecare Consulting, we encourage all agencies to belong to their respective state associations as well as NAHC. There is a wealth of education, advocacy, and resources for agencies. If you need individual consulting or education, please call Kenyon Homecare Consulting at 206-721-5091 or contact us online to see if we can help you achieve your clinical, operational, and financial goals.