Table of Contents Admissions

Introduction

As the COVID-19 pandemic has developed throughout the country, CMS has been working to provide answers to the many questions providers have had in providing care in this new environment. What does telehealth mean? How can I provide care to patients virtually? What should I put on the claim form? And what with the Office of Civil Rights allow as HIPAA exceptions during the pandemic?

NHPCO has been hard at work advocating for hospice providers, seeking answers, asking questions, asking for clarifications to questions, and developing resources. NHPCO has offered webinars on a myriad of topics, from regulatory changes to how care can be provided virtually. In an effort to put many of the questions and the answers from CMS or others in an easy- to-read format, NHPCO has compiled this list of questions from members, the answers as we know them today, and the links to the document/transcript/podcast where the answer was given.

This is an ever-changing document – NHPCO will add questions and answers as we get updates in the days and weeks ahead. Note the date and number at the bottom of the page to ensure that you have the latest date and the latest version. We hope that the FAQs presented here will help with the delivery of hospice care and answer care and billing questions. For more information or to ask a question not included here, please contact [email protected].

Table of Contents Admissions ...... 2 Assisted Living Facilities ...... 3 Audits ...... 4 Billing ...... 4 Comprehensive Assessment and Updates to Comprehensive Assessment ...... 6 Core Services ...... 7 Cost Reporting ...... 7 Face-to-Face Encounter ...... 7 Hospice Inpatient Facilities ...... 10 Hospice Quality Reporting Program ...... 12 Initial Assessment ...... 12 Non-Clinical Staff ...... 14 Nursing Homes and Hospice...... 15

PPE ...... 18 Return to Work ...... 20 Routine Home Care (RHC) ...... 20 Signatures ...... 24 Technology and HIPAA Compliance ...... 25 Telecommunications Technology ...... 26 Telehealth ...... 26 Testing and Screening...... 26 Volunteers ...... 27

Question Answer CMS Reference Admissions Can hospice complete a video/audio Virtual Hospice providers must use their best judgment in determining if Published: April 6, 2020 Hospice Initial Nursing Comprehensive they could gather enough information without an in person visit Effective March 1, 2020 Assessment when patients desire hospice to do an admission, and to ensure continuity and quality care for Interim Final Rule with Comment services, are eligible but are restricted to their patients and families. Hospices should document how the § 418.204 Special coverage requirements. complete an in-person admission by the RN? goals of care are met in a safe and appropriate manner. (d) Use of technology in furnishing services during a Public Health Emergency. When a patient is receiving routine home care, during a Public Health Emergency as defined in § 400.200 of this chapter, hospices may provide services via a telecommunications system if it is feasible and appropriate to do so to ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions.

The use of such technology in furnishing services must be included on the plan of care, meet the requirements at § 418.56, and must be tied to the patient-specific needs as identified in the comprehensive assessment and the plan of care must include a description of how the use of such technology will help to achieve the goals outlined on the plan of care.

Question Answer CMS Reference

Q: So, the initial assessment for hospice Yes. However, hospice providers must use their best judgment in April 7, 2020 admission can be done through telehealth? determining if they could gather enough information without an Transcript from the April 7, 2020 CMS Office Hours with in person visit to do an admission, and to ensure continuity and Hospitals and Health Systems quality care for their patients and families. Hospices should Click on April 7, 2020 Office Hours and open the transcript. document how the goals of care are met in a safe and appropriate manner. CMS: Right. I don't believe that we have a requirement that it has to be face-to-face, and so we're including that within the telehealth rubric as well.

CMS: From Danielle, I would just want to add onto that, that is correct that hospices may use telehealth to do this, to the extent that the use of telehealth is actually capable of providing a full assessment of a patient and caregiver's needs, and that's really what it comes down to as far as compliance with the CoPs is concerned. Were you able to fully assess the patient's needs in a way that allows you to develop an accurate care plan and deliver services? Assisted Living Facilities Can an assisted living facility/independent living CMS does not regulate assisted living and independent living June 11, 2020 facility restrict hospice staff from caring for a facilities. They do not participate in the Medicare or Medicaid Coronavirus 19 Disease (COVID-19) CMS Frequently Asked hospice patient in their facility during this COVID- programs. Hospice providers are encouraged to coordinate with Questions for Non-Long-Term Care Facilities and 19 PHE? assisted living/independent living facilities to assure that core Intermediate Care Facilities for Individuals with Intellectual services related to direct clinical care can be provided in an Disabilities (ICFs/IIDs) (CMS) appropriate and safe manner. Hospices serve an important role in providing essential healthcare services in a variety of community- based settings, including assisted and independent living facilities, and should be granted access as long as their staff meet the CDC guidelines for healthcare workers. If hospice staff are appropriately wearing PPE, and do not meet criteria for restricted access based on CDC guidance, they should be allowed to enter and provide services to the patient, see https://www.cdc.gov/coronavirus/2019-ncov/hcp/long-term- care.html.

Additionally, hospice personnel should participate with any screening activity that the facility requires. If access is restricted, hospices should communicate with the facility administration, including the State or local health department when indicated, on

Question Answer CMS Reference the nature of the restriction and timing for gaining access to hospice patients. Communication should also occur with the hospice patient’s family or representative. This communication is essential for maintaining surveillance and preventing the spread of infection while also ensuring access of patients to essential services.

If after reasonable attempts have been made and documented in the patient’s record and the hospice continues to be unable to access the patient in-person, the hospice would have to discharge the patient as “outside of the hospice’s service area” (Medicare Benefit Policy Manual, chapter 9, 20.2.3): https://www.cms.gov/regulations-and- guidance/guidance/manuals/downloads/bp102c09.pdf.

Additionally, a hospice must forward to the patient’s attending physician a copy of the hospice discharge summary and patient’s clinical record if requested. Guidance provided for those with chronic and serious illness can be found here: https://www.cdc.gov/coronavirus/2019-ncov/specific- groups/high-risk-complications.html. Additionally, CDC provides the following recommendations for clinicians: https://www.cdc.gov/coronavirus/2019- ncov/hcp/clinical-guidance-managementpatients.html Audits Is there a plan for when TPE reviews and other CMS expects to discontinue exercising enforcement discretion July 2020 audits will resume? beginning on August 3, 2020, regardless of the status of the https://www.cms.gov/files/document/provider- public health emergency. This includes prepayment TPE reviews conducted by the MACs, as well as post payment reviews burden-relief-faqs.pdf conducted by the MACs, Supplemental Medical Review Contractor (SMRC) reviews and Recovery Audit Contractors (RAC). Billing Since hospices are currently billing under the No April 14, 2020 MAC/NHPCO Call 1135 blanket waivers put in place for hospice, Per the MACs, no condition code DR is necessary for hospice should our hospice/institutional claims for dates claims. of service 3/1 and after including the condition code DR?

Question Answer CMS Reference Can hospice use COVID-19 positive as the primary  As of April 1, a specific ICD-10 code has been established for April 3, 2020 hospice diagnosis? We are seeing this IC10 patients with COVID-19: U07.1 Announced in MLN Matters, April 3, 2020 rejected when attempting to bill claims and is the  This “U” chapter is entitled “Reserved for future use” true hospice diagnosis resulting in death.  To be used as primary if known positive  List additional effects of infection, such as pneumonia after U07.1, such as “other viral pneumonia- J12.89”  Do not use U07.1 if only “suspected”  Use the symptom codes Will a hospice’s claim be paid if there are no visits Yes April 9, 2020 recorded on the claim? From the April 9, 2020 CMS COVID-19 Town Hall

Question on filing a claim if there are no visits on the claim: >>Speaker: So for hospice is unable to render physical visits to patients, individual patients and they are able to meet the patient need with telehealth initial assessments and comprehensive assessments that we've been instructed not to put on the claim so when a claim has been submitted there are zero visits on the claim. I just -- I'm just checking to ensure that

A. Again, initial and comprehensive assessments can be done via telehealth, B. your instructions to not put them on the claims are still in place and C. that then the claims will process without issues.

>>CMS Speaker: Sure. Yes. So we received this question before and we did check and as long as you are putting the level of care on the claim along with the unit for that like the number of days for that level of care plus the Q codes the location the process will -- the claim will process without a G code for the visit so you should be okay.

Can hospices include services furnished using Only in-person visits (with the exception of social work telephone Updated May 27, 2020 telecommunications technology on the hospice calls) are to be reported on the hospice claim submitted to CMS Frequently Asked Questions – 5/27/2020 claim that it submits to Medicare for payment? Medicare for payment. For purpose of service intensity add-on (SIA) payments, only in-person visits performed by registered nurses and social workers provided during routine home care during the last seven days of life are eligible for these add-on payments. As a reminder, the SIA payments are made above and beyond the routine home care per diem payment amount. On the

Question Answer CMS Reference hospice cost report, hospices can report the costs of telecommunications technology used to furnish services under the routine home care level of care during the PHE for the COVID- 19 pandemic as “other patient care services” using Worksheet A, cost center line 46, or a subscript of line 46 through 46.19, cost center code 4600 through 4619, and identifying this cost center as “PHE for COVID-19”. New: 5/1/20 Will the 2% sequestration reduction for claims be Yes. CMS confirmed in the April 10 edition of MLN Connects, April 10, 2020 suspended? that, in keeping with Section 3709 of the CARES Act, the 2% Effective dates: Dates of service May 1, 2020 through payment adjustment will be temporarily suspended for all December 31, 2020 Medicare Fee-For-Service (FFS) claims due to sequestration. MLN Connects (April 10, 2020)

The suspension is effective for claims with dates of service from May 1 through December 31, 2020.

Comprehensive Assessment and Updates to Comprehensive Assessment How does hospice handle the fact that the facility A hospice 1135 blanket waiver extends the timeframe for the Announced April 21, 2020 or family may not have staff available to update to the comprehensive assessment to 21 days during the Effective date: March 1, 2020 complete virtual assessments or patient/family public health emergency. CMS COVID-19 1135 Blanket Emergency Declaration do not have smart phones or means to virtual Waivers telehealth; can phone assessments be If hospice is not allowed to enter the facility, and no assessments completed? can be completed in any format (including via Summary of Hospice 1135 Blanket Waivers telecommunication), the hospice would have to determine how can it can develop and maintain a safe and effective plan of care that is appropriately updated and meets the Condition of Participation.

Can hospices complete the initial and Assuming that the patient is receiving routine home care during Updated May 27, 2020 comprehensive assessments virtually or over the the initial and comprehensive assessment timeframe, furnishing CMS Frequently Asked Questions – 5/27/2020 phone during the PHE for the COVID-19 services using telecommunications technology (e.g., using two- pandemic? way audio-video telecommunications technology that allows for real-time interaction between the clinician and the patient, like FaceTime or Skype, or using audio-only or TTY telephone calls) would be compliant if such technology can be used to the extent that it is capable of resulting in a full assessment of the patient and caregiver’s needs to inform an individualized plan of care. The initial and comprehensive assessment are the foundation of the plan of care, laying out the patient and family needs/goals and outlining the plan for the delivery of these services. An in- person initial and comprehensive assessment is standard practice

Question Answer CMS Reference and crucial to establishing the patient-hospice relationship. During this PHE, we expect in most, but not all, situations that the initial and comprehensive assessment visits would be done in person (especially when assessing skin/wound care; uncontrolled pain/symptoms; effectively teaching patient/caregiver medication administration, etc.). The assessments must identify the physical, psychosocial, emotional, and spiritual needs related to the terminal illness that must be addressed in order to promote the hospice patient's well-being, comfort, and dignity throughout the dying process. The ultimate goal of these assessments is to fully identifying the needs of the patient and caregivers to establish an individualized patient-centered plan of care. New: 5/1/20 Core Services Given the current COVID-19 PHE, we have CMS currently allows for use of contracted staff, if necessary, to June 11, 2020 challenges with providing core services due to supplement hospice employees in order to meet the needs of Coronavirus 19 Disease (COVID-19) CMS Frequently Asked staff shortages and illness. Will CMS consider patients under extraordinary or other non-routine circumstances. Questions for Non-Long-Term Care Facilities and waivers to utilize contracted staff to address Furthermore, a hospice may also enter into a written Intermediate Care Facilities for Individuals with Intellectual these gaps during the PHE? arrangement with another Medicare certified hospice program Disabilities (ICFs/IIDs) (CMS) for the provision of core services to supplement hospice employee/staff to meet the needs of patients as described under 42 CFR 418.64, “Condition of participation: Core services.” Therefore, no waiver is required to use contracted services for this purpose. Cost Reporting Will CMS delay the filing deadline for cost reports Yes, 42 CFR 413.24 (f)(2)(ii) allows this flexibility. CMS will delay Updated May 27, 2020 impacted during the COVID-19 PHE? the filing deadline of Fiscal Year End (FYE) 10/31/2019 and FYE CMS Frequently Asked Questions – 5/27/2020 11/30/2019 cost reports until June 30, 2020. CMS will also delay the filing deadline of the FYE 12/31/2019 cost reports until July 31, 2020. In summary the extension impacts the following cost reporting fiscal year ends for all provider types (hospitals, SNFs, HHAs, hospices, ESRDs, RHCs, FQHCs, CMHCs, OPOs, histocompatibility labs and home office cost statements): New: 4/10/20 Face-to-Face Encounter Can I do a hospice face-to-face encounter through Yes Legislation passed and signed by President: March 27, telehealth? 2020

Question Answer CMS Reference Also mentioned In IFC Rule: April 6, 2020 Effective date: March 1, 2020  H.R. 748 – the CARES Act  NHPCO Policy Alert on Passage of the Coronavirus Aid, Relief, and Economic Security Act or the ‘‘CARES Act” What are the requirements for telehealth for the Face-to-face encounters must be conducted with audio-visual Legislation passed and signed by President: March 27, hospice face-to-face encounter? real time communication. No voice-to-voice without visual is 2020 allowed. Also mentioned In IFC Rule: April 6, 2020 Effective date: March 1, 2020  Medicare Telemedicine Health Care Provider Fact Sheet  The legislation (CARES Act) will allow face-to-face encounters for recertification for hospice care to be completed by hospice physicians and nurse practitioners using telehealth technologies during the emergency period. What if there are medically necessary services They can be provided just as they were before the pandemic. No change that are needed during the telehealth visit? How do I bill for medically necessary services Bill for medically necessary visits during the face-to-face as they No change when doing the face-to-face? were billed before the public health emergency. The only exam components that can be rendered (counted) are those that don’t take physical touch. . The clinician cannot auscultate the lungs or palpate a liver/spleen . (S)he can do an exam based on observational findings, e.g., scleral icterus, oral thrush, the appearance of distress, mood/affect and/or orientation. . If you are not able to conduct a physical exam at all, then you cannot bill a new patient E&M visit code unless you qualify to use time (> 50% of the time in C/CC).  The level of service depends on the documentation, just like a normal visit.  Use modifier 95 on telehealth E/M visit codes Can I do a face-to-face encounter through a Yes, but only if the phone has video capabilities, such as a smart April 9, 2020 telephone? phone with FaceTime. Answer from 4/9/2020 CMS Stakeholder call regarding face-to-face with just audio

Question Answer CMS Reference A: >>CMS Speaker: Sure, this is Hillary. The face to face encounter requirement for hospices is a statutory requirement so I think the agency is limited in its ability to waive that requirement either on a case-by-case basis or the blanket waiver. But as you mentioned we are considering whether there is additional flexibility that should be in place for the examples you mentioned like patients in rural areas that may not have access to the two way audiovisual so that is something we are taking another look at.

CMS Stakeholder Podcasts and Transcripts Click on April 9, 2020 CMS Office Hours Call What types of audio/visual communication are Common, non-public-facing applications like FaceTime or Skype Effective date: January 31, 2020 acceptable for the face-to-face encounter? are allowed to provide telehealth services during the public Issued: March 17, 2020 health emergency. Office of Civils Rights for HIPAA Discretion

Can you do face-to-face with just audio? No, audio and visual capability are required. April 9, 2020

Question from 4/9/2020 CMS Office Hours Call Answer from 4/9/2020 CMS Stakeholder call regarding regarding face-to-face with just audio. face-to-face with just audio Q: I know you are taking it under advisement for the patients who do live in rural areas have no A: >>CMS Speaker: Sure, this is Hillary. The face to face visual capacity because they don't have a smart encounter requirement for hospices is a statutory phone, or a tablet or Internet access only have a requirement so I think the agency is limited in its ability to land line. What do you suggest, should hospice waive that requirement either on a case-by-case basis or the submit an individual waiver request if they can blanket waiver. But as you mentioned we are considering only do an audio only telehealth visit for those whether there is additional flexibility that should be in place patients who need to be recertified? Thank you. for the examples you mentioned like patients in rural areas that may not have access to the two way audiovisual so that is something we are taking another look at.

CMS Stakeholder Podcasts and Transcripts Click on April 9, 2020 CMS Office Hours Call CMS clarification of Face-to-Face Requirements April 14, 2020 for Hospice CMS Stakeholder Podcasts and Transcripts Click on the April 14 Home Health and Hospice Call Can hospice physicians/hospice nurse Hospices are allowed to use 2-way audio-video Updated May 27, 2020 practitioners conduct the required face-to-face telecommunications technology that allows for real-time CMS Frequently Asked Questions – 5/27/2020 encounter for re-certifications using interaction between the patient and the clinician (e.g., FaceTime, telecommunications technology? Skype) to satisfy the face-to-face encounter requirement, which is

Question Answer CMS Reference required for the third benefit period (after the patient has typically been receiving hospice for six months) and each subsequent 60-day benefit period thereafter. An explanation of why the clinical findings from the hospice face-to-face encounter support that the patient still has a life expectancy of six months or less is required as part of the recertification narrative. We do not believe that telephone calls (audio only or TTY) would provide the necessary clinical information for a hospice physician to determine whether the patient continues to have a life expectancy of six months or less. As such, telephone calls (audio only or TTY) cannot be used to satisfy the hospice face-to-face encounter requirement. New: 5/1/20 Flexibilities What flexibilities are there for hospices during On March 30, 2020, CMS released the interim final rule with June 11, 2020 the COVID-19 PHE? comment period, “Medicare and Medicaid Programs; Policy and Coronavirus 19 Disease (COVID-19) CMS Frequently Asked Regulatory Revisions in Response to the COVID-19 Public Health Questions for Non-Long-Term Care Facilities and Emergency” (85 FR 19230). Pursuant to section II.H of that Intermediate Care Facilities for Individuals with Intellectual interim final rule, (85 FR 19250), CMS is expanding access to Disabilities (ICFs/IIDs) (CMS) telehealth services for people with Medicare during the COVID-19 PHE. For more information, consult the Interim Final Rule document at the Coronavirus Waivers & Flexibilities website: https://www.cms.gov/files/document/covid-final-ifc.pdf.

CMS has also announced the release of several blanket waivers intended to provide flexibilities for hospices during the public health emergency for COVID-19. Individual waiver requests will be reviewed by CMS on a case by case basis. CMS continues to update the blanket waivers. We recommend monitoring the website for updates at https://www.cms.gov/files/document/summary-covid-19- emergency-declarationwaivers.pdf.

Hospice Inpatient Facilities When is it safe to discontinue Transmission-based The decision to discontinue Transmission-Based Precautions for June 11, 2020 Precautions for inpatient hospice patients with inpatient hospice patients with COVID-19 should be made in Coronavirus 19 Disease (COVID-19) CMS Frequently Asked COVID-19 or in-home isolation for in home accordance with the CDC guidelines available at Questions for Non-Long-Term Care Facilities and hospice patients with COVID-19? https://www.cdc.gov/infectioncontrol/basics/transmission- Intermediate Care Facilities for Individuals with Intellectual based-precautions.html. Disabilities (ICFs/IIDs) (CMS)

Question Answer CMS Reference The decision to discontinue in-home isolation for in home hospice patients with COVID-19 should be made in the context of local circumstances. For more information, see https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition- inhome- patients.html. Are there any changes in the CoPs for hospice Yes, to reduce disruption of patient care and potential exposure/ May 11, 2020 inpatient care in the physical environment transmission of COVID-19. The physical environment regulations Effective date: March 1, 2020 through the end of the public inspection, testing and maintenance? require that facilities and equipment be maintained to ensure an health emergency. acceptable level of safety and quality. CMS will permit facilities to CMS Issues Additional 1135 Blanket Waivers adjust scheduled inspection, testing and maintenance (ITM) frequencies and activities for facility and medical equipment.

Are there any waivers in the Life Safety Code Yes, CMS is waiving and modifying particular waivers at May 11, 2020 CoPs for inpatient hospice? §418.110(d) for inpatient hospice. A summary of the waivers Effective date: March 1, 2020 through the end of the public follows. Please be sure to read the complete text of the waiver health emergency. allowances. CMS Issues Additional 1135 Blanket Waivers a. Alcohol-based Hand-Rub (ABHR) Dispensers: We are waiving the prescriptive requirements for the placement of alcohol-based hand rub (ABHR) dispensers for use by staff and others due to the need for the increased use of ABHR in infection control. b. Fire Drills: Due to the inadvisability of quarterly fire drills that move and mass staff together, we will instead permit a documented orientation training program related to the current fire 27 5/11/2020 1 plan, which considers current facility conditions. Temporary Construction: CMS is waiving requirements that would otherwise not permit temporary walls and barriers between patients.

Question Answer CMS Reference Hospice Quality Reporting Program Hospice Quality Reporting Program (HQRP)  Exemption for submission of HIS and CAHPS data March 27, 2020 Guidance  For HIS, the quarters are based on submission of HIS MLN Connects Newsletter: admission or discharge assessments. Exceptions and Extensions for Quality Reporting Requirements for Acute Care Hospitals, PPS-Exempt Cancer  For CAHPS, the quarters are based on patient deaths in 2019 Hospitals, Inpatient Psychiatric Facilities, Skilled Nursing and 2020. Hospice QRP: o October 1, 2019–December 31, Facilities, Home Health Agencies, Hospices, Inpatient 2019 (Q4 2019) o January 1, 2020–March 31, 2020 (Q1 2020) Rehabilitation Facilities, Long-Term Care Hospitals, o April 1, 2020–June 30, 2020 (Q2 2020) Ambulatory Surgical Centers, Renal Dialysis Facilities, and  No 2% penalty for non-submission MIPS Eligible Clinicians Affected by COVID-19 (March 27, 2020)

Updated Hospice Quality Reporting Program  HQRP reporting will resume on July 1, 2020 for all new June 23, 2020 Guidance HIS admission records and any HIS discharge records Reminder from CMS – June 23, 2020 that occur on or after July 1, 2020.  The data collection for this year calendar year is from HQRP_COVID-19 PHE_Tipsheet_July 2020_508- compliant (PDF) July 1 through December 31, 2020 and compliance will be based on these dates.

Initial Assessment Please address conducting initial  Documentation must be individualized to the patient IFC published April 6, 2020 assessment/admission visit and completion of and situation and indicated in the plan of care. Effective date: March 1, 2020 the comprehensive assessment within 5 days of Interim Final Rule with Comment admission via telehealth audio and video capability § 418.204 Special coverage requirements. (d) Use of technology in furnishing services during a Public Health Emergency. When a patient is receiving routine home care, during a Public Health Emergency as defined in §

Question Answer CMS Reference 400.200 of this chapter, hospices may provide services via a telecommunications system if it is feasible and appropriate to do so to ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions.

Can hospices complete the initial and  Assuming that the patient is receiving routine home Updated May 27, 2020 comprehensive assessments virtually or over the care during the initial and comprehensive assessment CMS Frequently Asked Questions – 5/27/2020 phone during the PHE for the COVID-19 timeframe, furnishing services using pandemic? telecommunications technology (e.g., using two-way audio-video telecommunications technology that allows for real-time interaction between the clinician and the patient, like FaceTime or Skype, or using audio-only or TTY telephone calls) would be compliant if such technology can be used to the extent that it is capable of resulting in a full assessment of the patient and caregiver’s needs to inform an individualized plan of care. The initial and comprehensive assessment are the foundation of the plan of care, laying out the patient and family needs/goals and outlining the plan for the delivery of these services. An in-person initial and comprehensive assessment is standard practice and crucial to establishing the patient-hospice relationship.

 During this PHE, we expect in most, but not all, situations that the initial and comprehensive assessment visits would be done in person (especially when assessing skin/wound care; uncontrolled pain/symptoms; effectively teaching patient/caregiver medication administration, etc.). The assessments must identify the physical, psychosocial, emotional, and

Question Answer CMS Reference spiritual needs related to the terminal illness that must be addressed in order to promote the hospice patient's well-being, comfort, and dignity throughout the dying process. The ultimate goal of these assessments is to fully identifying the needs of the patient and caregivers to establish an individualized patient-centered plan of care. New: 5/1/20 Non-Clinical Staff Are telehealth visits for social workers recordable Only SW phone calls can be recorded on the hospice claim form. No change on the hospice claim? Chapter 11 – Hospice Claims Processing Manual SW phone calls during the last 7 days of life cannot be billed for SIA. SIA Citation: 30.2.2 – Service Intensity Add-on (SIA) Payments (Rev. 3502, Issued: 04-28-16, Effective: 01- 01-16, Implementation: 10-03-16) Social workers, bereavement and chaplains are Yes, CMS confirms that visits by all disciplines (with the exception April 7, 2020 not doing in person visits unless an absolute of hospice aides) for patients in routine home care (RHC) can be CMS Office Hours, April 7 2020 necessity, most pts/families/clients do not want conducted voice-to-voice, or “via a telecommunications system if Click on April 7, CMS Office Hours with Hospitals and Health us in person. They are trying to do video, but it is feasible and appropriate to do so…” Systems most pts/families/clients do not want to do video Q: OK. I'm calling from the California Hospice Association, or do not have capability and want to do phone Hospice providers must use their best judgment in determining and our question is regarding Medicare telehealth and the calls only. What does this mean for us as far as how they can gather enough information without an in-person waiver that was approved for flexibility, which is that we can meeting regulations? visit, and to ensure continuity and quality care for their patients provide telehealth under the routine home care, or a face to and families. Hospices should document how the goals of care face encounter with a nurse practitioner or an MD or a DO. will be, and are, met in a safe and appropriate manner. And I want to confirm that it can be a voice to voice mechanism for telehealth. We do not have, and most of our patients in families' homes do not have the capacity to do any video. They mostly use landlines. So, can you confirm for me that hospice providers can use voice to voice in the routine home care telehealth as well as the face to face encounter?

A: CMS Staff: Hey there, I can jump in. You can use a landline for routine home care visits in lieu of an in-person visit, but it's for the face to face requirement right now, we're requiring the two-way audio/visual communication, but I can definitely take your concerns down and see if there's any potential for revisiting that in the future.

Question Answer CMS Reference Q: Female: OK, so can you can confirm that we can use voice to voice?

A: CMS Staff: You can – you can use voice to voice for RHC days.

IFC published April 6, 2020 Effective date: March 1, 2020 Interim Final Rule with Comment

§ 418.204 Special coverage requirements. (d) Use of technology in furnishing services during a Public Health Emergency. When a patient is receiving routine home care, during a Public Health Emergency as defined in § 400.200 of this chapter, hospices may provide services via a telecommunications system if it is feasible and appropriate to do so to ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions.

Nursing Homes and Hospice Previous guidance provided for hospice patients CMS considers hospice workers providing specialized palliative June 11, 2020 residing in nursing homes referenced and end-of-life care to be essential healthcare workers. Hospice Coronavirus 19 Disease (COVID-19) CMS Frequently Asked “Compassionate Care” visits but many of our staff should be permitted to come into a facility as long as they Questions for Non-Long-Term Care Facilities and hospice providers who serve patients in this meet the CDC guidelines for health care workers. CMS has Intermediate Care Facilities for Individuals with Intellectual setting have been told they are not considered reinforced this guidance for nursing homes in our recent Disabilities (ICFs/IIDs) (CMS) essential personnel and have been prevented memoranda referenced below. CMS recognizes that hospice from entering the facility. Can CMS provide any providers play an essential service in the care of those with additional guidance? terminal illnesses and encourages providers to work

Question Answer CMS Reference collaboratively with facility staff to provide needed care in a safe and appropriate manner that is consistent with current CDC guidance for health care workers. Guidance and FAQs related to nursing homes are available at https://www.cms.gov/files/document/qso-20-14-nh- revised.pdf and https://www.cms.gov/files/document/qso-20- 28-nh.pdf.

Did CMS issue new guidance for nursing homes Yes, they issued a series of FAQs with recommendations for May 18, 2020 on reopening? nursing home reopening. Nursing Home Reopening Recommendations Frequently Asked Questions What steps should nursing homes take before Nursing homes should continue to follow CMS and CDC guidance May 18, 2020 reopening to visitors? for preventing the transmission of COVID-19. In addition, they Nursing Home Reopening Recommendations Frequently should follow state and local direction. Because nursing home Asked Questions residents are especially vulnerable, CMS does not recommend opening facilities to visitors (except for compassionate care situations) until phase three when:  there have been no new, nursing home onset COVID-19 cases in the nursing home for 28 days (through phases one and two)  the nursing home is not experiencing staff shortages  the nursing home has adequate supplies of personal protective equipment and essential cleaning and disinfection supplies to care for residents  the nursing home has adequate access to testing for COVID- 19  referral hospital(s) have bed capacity on wards and intensive care units What should hospices do? The Administration has given authority to the states for May 18, 2020 reopening, including nursing facilities. Be sure to check state and Nursing Home Reopening Recommendations Frequently local guidelines for reopening and for testing. Asked Questions What about testing for nursing home staff and Staff: All staff should receive a baseline test and continue to be May 18, 2020 residents? tested weekly. Nursing Home Reopening Recommendations Frequently Residents: Nursing homes should have a comprehensive plan for Asked Questions testing. All residents should receive a single baseline test for COVID-19. Also, all residents should be tested upon identification of an individual with symptoms consistent with COVID-19 or if an employee or staff member tested positive for COVID-19. Does the facility need to inform anyone who A: No. Facilities are not required to provide the same COVID-19 May 6, 2020 walks through their doors (e.g. a hospice or information reported to residents, their representatives, and

Question Answer CMS Reference healthcare provider) of the same numbers of families. However, facilities would share with the visiting Interim Final Rule Updating Requirements for Notification suspected and confirmed COVID-19 cases that healthcare provider, if the resident receiving care is suspected of, of Confirmed and Suspected COVID-19 Cases Among they are sharing with residents, their or has laboratory confirmed COVID-19. Any precautions the Residents and Staff in Nursing Homes representatives and families? provider should take while in the facility (e.g., specific personal protective equipment) will be communicated to that provider by the facility as part of their standard practices under the infection prevention and control program requirement. What if no one can enter the nursing home to If hospice is not allowed to enter the facility, and no assessments April 24, 2020 provide care? can be completed in any format (including via Latest CMS guidance and FAQs for nursing home providers telecommunication), the hospice would have to determine how (April 24, 2020) can it can develop and maintain a safe and effective plan of care that is appropriately updated and meets the Condition of FAQs related to hospice in nursing homes: Participation. COVID-19 Update, April 24, 2020

In the April 24, 2020 guidance, CMS encourages frequent communication among patients, residents, families, facilities, and other health care providers when appropriate (e.g., hospice providers), so they can work together to identify when a visit for compassionate care is needed and can be safely conducted. One example of such a situation is one in which a resident is receiving hospice care and their health status is sharply declining, or when a resident is not enrolled in hospice, but their health status has sharply declined. In these circumstances, it is necessary to ensure precautions are taken to conduct visits as safely as possible, including following practices for hand hygiene and use of PPE. What does CMS say about nursing homes CMS has encouraged nursing homes to allow hospice workers in. April 24, 2020 allowing hospice workers in? As the COVID-19 pandemic has spread, nursing homes are asking Nursing Home Five Star Quality Rating System updates, hospice workers to provide their care through audio/visual or Nursing Home Staff Counts, and Frequently Asked through phone calls without entry into the facility. Questions (April 24, 2020)

The guidance to nursing homes from CMS has changed over the April 9, 2020 course of the pandemic. In the most recent guidance on April 24, Joint Statement from the American Health Care 2020, CMS is also encouraging nursing homes to offer telephonic Association, the National Center for Assisted Living and or digital means of communications. NHPCO

Do facilities need to inform anyone who walks No. Facilities are not required to provide the same COVID-19 May 6, 2020 through their doors (e.g., a hospice or other information reported to residents, their representatives, and CMS guidance memo to State Survey Agencies on Interim healthcare provider) of the same numbers of families. However, facilities would share with the visiting Final Rule Updating Requirements for Notification of

Question Answer CMS Reference suspected and confirmed COVID-19 cases that healthcare provider, if the resident receiving care is suspected Confirmed and Suspected COVID-19 Cases Among they are sharing with residents, their of, or has laboratory confirmed COVID-19. Any precautions the Residents and Staff in Nursing Homes (May 6, 2020) representatives, and families? provider should take while in the facility (e.g., specific personal protective equipment) will be communicated to that provider by the facility as part of their standard practices under the infection prevention and control program requirement.

When would a hospice live discharge a patient The hospice would discharge the patient when they are unable to July 1, 2020 utilizing the discharge code “outside of the access the patient either through in person visits or June 2020 FAQ for non LTC and ICF/IIFs hospice’s service area” if unable to access the telecommunication and are unable to update the patient’s plan patient in the facility? of care. COVID 19 Emergency Declaration Waivers

CMS encourages providers to utilize the current waivers and previous published guidance in conjunction with in-person visits to meet the needs of the individual.

CMS also recommends that providers use the CMS Quality Safety and Oversight Group resource mailbox [email protected] to address specific issues they encounter regarding facility access

PPE Given the current COVID-19 PHE, we are CMS recognizes that volunteer services represent an essential June 11, 2020 concerned with having enough PPE to provide component of the current hospice benefit and provide invaluable Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers given current shortages and concern services to the patients. Given the current PHE, CMS is waiving Questions for Non-Long-Term Care Facilities and for potential exposure. Additionally, we have the requirement that hospices be required to use volunteers Intermediate Care Facilities for Individuals with Intellectual heard some patients are not allowing any visits (including at least 5% of patient care hours). Alternatively, Disabilities (ICFs/IIDs) (CMS) and our providers are concerned about meeting hospice providers may continue to utilize volunteers in other non- the 5% of patient care hours for volunteers direct care activities (e.g. administration activities) and consider during the PHE. using the flexibilities allowing for use of telecommunications technologies to further facilitate ways in which volunteers can continue to support the patients served, however, this is not required during the COVID-19 PHE. How should hospice programs monitor or restrict Please refer to the CDC guidance for exposures that might June 11, 2020 health care staff or hospice volunteers? warrant restricting asymptomatic healthcare personnel or Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers from reporting to work Questions for Non-Long-Term Care Facilities and (https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance- Intermediate Care Facilities for Individuals with Intellectual risk-assesment-hcp.html) Disabilities (ICFs/IIDs) (CMS)

Question Answer CMS Reference Hospices should contact their local health department for questions, and frequently review the CDC website dedicated to COVID-19 for health care professionals (https://www.cdc.gov/coronavirus/2019- nCoV/hcp/index.html).

Hospices making decisions about return to work for their healthcare professionals with confirmed COVID-19, or who have suspected COVID-19 (e.g., developed symptoms of a respiratory infection such as cough, sore throat, shortness of breath, or fever but did not get tested for COVID-19) should be made according to the CDC guidelines available at https://www.cdc.gov/coronavirus/2019-ncov/healthcare- facilities/hcp-return-work.html.

Strategies for optimizing PPE upon return to work for hospice health care personnel (HCPs) who had confirmed or suspected COVID-19 can be located on the CDC website at https://www.cdc.gov/coronavirus/2019-ncov/hcp/ppe- strategy/index.html.

What Personal Protective Equipment (PPE) If care provided to patients who are confirmed or suspected to be June 11, 2020 should hospice staff routinely use when visiting COVID-19 positive is anticipated, then Hospice Agencies should Coronavirus 19 Disease (COVID-19) CMS Frequently Asked the home of a patient with suspected or refer to the CDC Interim Infection Prevention and Control Questions for Non Long Term Care Facilities and confirmed COVID-19 exposure? Recommendations for Patients with Suspected or Confirmed Intermediate Care Facilities for Individuals with Intellectual Coronavirus Disease 2019 (COVID-19) in Healthcare Settings: Disabilities (ICFs/IIDs) (CMS) https://www.cdc.gov/coronavirus/2019-ncov/infectioncontrol/controlrecommendations.html.

Hospices experiencing a shortage of PPE should engage their local and state health and emergency management departments for assistance. To identify local health departments supporting preparedness and response activities, visit the National Association for County and City Health Officials Directory of Local Health Departments at https://www.naccho.org/membership/lhd-directory.

Does Medicare pay health care providers such as Not directly. Medicare payments for health care services include Updated May 27, 2020 hospices, hospitals, and skilled nursing facilities payment for the supplies necessary to appropriately provide the CMS Frequently Asked Questions – 5/27/2020 (SNFs) separately for personal protective service, including any personal protective equipment and supplies

Question Answer CMS Reference equipment and supplies necessary to prevent the appropriate for the patient's condition and treatment. However, spread of infectious disease? there are not separate payments for those supplies. Additional resources for infection control, such as supplies or staffing assistance, may be made available from other local, state, or federal government agencies. Revised: 4/10/20 Return to Work How should hospice programs monitor or restrict Please refer to the CDC guidance for exposures that might June 11, 2020 health care staff or hospice volunteers? warrant restricting asymptomatic healthcare personnel or Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers from reporting to work Questions for Non Long Term Care Facilities and (https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance- Intermediate Care Facilities for Individuals with Intellectual risk-assesment-hcp.html) Disabilities (ICFs/IIDs) (CMS)

Hospices should contact their local health department for questions, and frequently review the CDC website dedicated to COVID-19 for health care professionals (https://www.cdc.gov/coronavirus/2019- nCoV/hcp/index.html).

Routine Home Care (RHC) When is it safe to discontinue Transmission-based The decision to discontinue Transmission-Based Precautions for June 11, 2020 Precautions for inpatient hospice patients with inpatient hospice patients with COVID-19 should be made in Coronavirus 19 Disease (COVID-19) CMS Frequently Asked COVID-19 or in-home isolation for in home accordance with the CDC guidelines available at Questions for Non Long Term Care Facilities and hospice patients with COVID-19?

Question Answer CMS Reference https://www.cdc.gov/infectioncontrol/basics/transmission- Intermediate Care Facilities for Individuals with Intellectual based-precautions.html. Disabilities (ICFs/IIDs) (CMS) The decision to discontinue in-home isolation for in home hospice patients with COVID-19 should be made in the context of local circumstances. For more information, see https://www.cdc.gov/coronavirus/2019-ncov/hcp/disposition- inhome- patients.html.

Can I do an RHC visit using the phone? Yes. The referenced language is “via a telecommunications April 21, 2020 system if it is feasible and appropriate to do so…” Confirmation of this question and the CMS answer on the April 21 2020 Home Health and Hospice Stakeholder Call. Jean Moody-Williams, CMS Center for Clinical Standards and Quality read the question and provided the answer. Here is the transcript:

Q: Can CMS include all hospice services to be provided virtually through telephone and telehealth modalities as determined by the hospice planning care, including visits from all hospice disciplines including nurses, social workers, spiritual services, bereavement and other counseling. Are there any other types of services specified in the plan of care?

A: The answer is that hospices may provide any services via telemedicine or audio only as long as the patient is receiving routine home care (RHC) level of care and those telemedicine services which are audio only services are capable of meeting the patient and caregiver needs. You [the hospice] are really going to be the best judge of that. There are some things where, of course, they are going to require an in-person visit to meet the needs of the patient and some that can be done by telemedicine and basically it is permissible to do that when it is advisable to have a telemedicine visit.

IFC published April 6, 2020 Effective date: March 1, 2020 Interim Final Rule with Comment

§ 418.204 Special coverage requirements.

Question Answer CMS Reference (d) Use of technology in furnishing services during a Public Health Emergency. When a patient is receiving routine home care, during a Public Health Emergency as defined in § 400.200 of this chapter, hospices may provide services via a telecommunications system if it is feasible and appropriate to do so to ensure that Medicare patients can continue receiving services that are reasonable and necessary for the palliation and management of a patients’ terminal illness and related conditions.

What disciplines can use the phone to do an RHC All disciplines (with the exception of a hospice aide) April 21, 2020 visit? Confirmation of this question and the CMS answer on the April 21 2020 Home Health and Hospice Stakeholder Call. Jean Moody-Williams, CMS Center for Clinical Standards and Quality read the question and provided the answer. Here is the transcript:

Question Answer CMS Reference and some that can be done by telemedicine and basically it is permissible to do that when it is advisable to have a telemedicine visit.

IFC published April 6, 2020 Effective date: March 1, 2020 Interim Final Rule with Comment

Can I put the RHC telephone visits on the claim No disciplines except social worker phone calls can be entered on No change form? the claim form. Chapter 11 – Hospice Claims Processing Manual

Hospices report social worker phone calls and all visits performed by hospice staff in 15-minute increments using the following revenue codes and associated HCPCS. This includes visits by hospice nurses, aides, social workers, physical therapists, occupational therapists, and speech- language pathologists

Social Worker Phone Calls Citation: 30.3 - Data Required on the Institutional Claim to A/B MAC (HHH) (Rev. 4393, Issued:

Question Answer CMS Reference 09- 13-19: Effective: 11-25-19, Implementation: 11-25-19) See Revenue Codes Section What telephone or telehealth visits can count on Only social worker phone calls can be entered on the claim form. No change the claim form? No social worker phone calls during the last 7 days of life can be Chapter 11 – Hospice Claims Processing Manual billed for the SIA payment. SIA Citation: 30.2.2 – Service Intensity Add-on (SIA) Payments (Rev. 3502, Issued: 04-28-16, Effective: 01- 01-16, Implementation: 10-03-16) Signatures Have there been any flexibilities in requirements No. April 21, 2020 for signatures on consents? People don't want to Audio from CMS Home Health and Hospice Stakeholder meet, haven't got the technology to do by phone Call – April 21 2020 and the delays from even overnight mail are having an impact on being able to provide timely Q: I was wondering both on the hospice side and CMS side care. so a question if there's been any flexibility regarding obtaining patient consent specifically with signature and a question for the presenters on how you guys are handling that. A: This is Karen from the CMS Quality Safety Oversight Group. We have talked about that in terms of the requiring the signature. I don't believe there is anything in the conditions of participation for that but there may be a payment related issue there in terms of that signature and I don't know if anybody is available from the payment side.

>>Speaker: This is Hilary Loeffler. On the payment side. So right now, we are still requiring signature to elect the hospice benefit. It's very important because they need to have the Medicare payment made on their behalf to any other provider it's important that patient be fully informed of this.

As a hospice providing attending physician and The patient must verbally consent to receive virtual check-in March 17, 2020 APN services, do we need to get consent from the services. There is no reason to obtain the patient’s consent each Medicare Telemedicine Healthcare Provider Fact Sheet patient/family to do a telehealth visit every time time a telehealth visit is provided. (March 17, 2020) an attending physician/APN visit is made? This was clarified in the Interim Final Rule with Comment:

Question Answer CMS Reference “Therefore, on an interim basis, during the PHE for the COVID-19 pandemic, we are finalizing that these services, which may only be reported if they do not result in a visit, including a telehealth visit, can be furnished to both new and established patients. We are also making clear that the consent to receive these services can be documented by auxiliary staff under general supervision. While we continue to believe that beneficiary consent is necessary so that the beneficiary is notified of any applicable cost sharing, we do not believe that the timing or manner in which beneficiary consent is acquired should interfere with the provision of one of these services. Therefore, we are finalizing on an interim basis during the PHE for the COVID-19 pandemic that, while consent to receive these services must be obtained annually, it may be obtained at the same time that a service is furnished. We are also re-emphasizing that this consent may be obtained by auxiliary staff under general supervision, as well as by the billing practitioner.”

Do providers need to obtain Beneficiary consent should not interfere with the provision of March 30, 2020 patient/representative consent for a telehealth telehealth services. Annual consent may be obtained at the same CMS Waiver Guidance visit? time, and not necessarily before, the time that services are Physicians and Other Clinicians: CMS Flexibilities to Fight furnished. COVID-19 (March 30, 2020) Technology and HIPAA Compliance Is Google Duo an allowed video call app? It is possible only if it is private and not public facing. Office of Civils Rights for HIPAA Discretion

Is Zoom an acceptable platform? Yes Office of Civils Rights for HIPAA Discretion

How is Face Time HIPAA compliant? The Office of Civil Rights has relaxed the rules regarding HIPAA Office of Civils Rights for HIPAA Discretion compliance during the public health emergency.

Applications allowed: Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype. However, public facing communication should not be used in the provision of telehealth. Are there restrictions on media and film crew The HIPAA Privacy Rule does not permit them to give media and Office of Civils Rights for HIPAA Discretion access in facilities? film crews access to facilities where patients’ protected health information (PHI) will be accessible without the patients’ prior authorization.

Question Answer CMS Reference Is there any guidance from HHSS/OCRR updated their guidance to health entities covered by May 15, 2020 the federal government related to LEP and OCR’s civil rights authorities to ensure they are better able to Office of Civil Rights Bulletins Related to COVID-19 COVID-19? serve individuals with limited English proficiency (LEP). Telecommunications Technology Can hospices furnish services using Yes. Hospices are able to furnish services using Updated May 27, 2020 telecommunications technology during the PHE telecommunications technology during the PHE when a patient is CMS Frequently Asked Questions – 5/27/2020 for the COVID-19 pandemic? receiving routine home care. This can include telephone calls (audio only or TTY), two-way audio-video telecommunications technology that allow for real-time interaction between the patient and clinician (e.g., FaceTime, Skype), and remote patient monitoring. It would be up to the clinical judgment of hospice as to whether such technology can meet the patient’s/caregiver’s/family’s needs and the use of technology should be included on the plan of care for the patient and family. New: 5/1/20 Telehealth Where can I find questions and answers on the For more information on the hospice care, see June 11, 2020 use of telehealth in hospice care? https://www.cms.gov/files/document/03092020-covid-19-faqs- Coronavirus 19 Disease (COVID-19) CMS Frequently Asked 508.pdf describing policies allowing for use of telehealth or Questions for Non-Long-Term Care Facilities and telecommunications technology in furnishing hospice care during Intermediate Care Facilities for Individuals with Intellectual the COVID-19 PHE. Disabilities (ICFs/IIDs) (CMS)

What is the definition of telehealth? March 17, 2020 CMS Frequently Asked Questions about Telehealth

Testing and Screening How should hospices screen patients for COVID- Hospices should identify patients at risk for having COVID-19 June 11, 2020 19 when the patient needs short-term inpatient infection before or immediately upon arrival to the hospice Coronavirus 19 Disease (COVID-19) CMS Frequently Asked care at a hospice inpatient facility? inpatient facility. Guidance for evaluating and testing patients for Questions for Non-Long-Term Care Facilities and COVID-19 infection can be found on the CDC website at: Intermediate Care Facilities for Individuals with Intellectual https://www.cdc.gov/coronavirus/2019-nCoV/hcp/clinical- Disabilities (ICFs/IIDs) (CMS) criteria.htm

How should hospice programs monitor or restrict Please refer to the CDC guidance for exposures that might June 11, 2020 health care staff or hospice volunteers? warrant restricting asymptomatic healthcare personnel or Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers from reporting to work Questions for Non-Long-Term Care Facilities and

Question Answer CMS Reference (https://www.cdc.gov/coronavirus/2019-ncov/hcp/guidance- Intermediate Care Facilities for Individuals with Intellectual risk-assesment-hcp.html) Disabilities (ICFs/IIDs) (CMS)

Volunteers Given the current COVID-19 PHE, we are CMS recognizes that volunteer services represent an essential June 11, 2020 concerned with having enough PPE to provide component of the current hospice benefit and provide invaluable Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers given current shortages and concern services to the patients. Given the current PHE, CMS is waiving Questions for Non-Long-Term Care Facilities and for potential exposure. Additionally, we have the requirement that hospices be required to use volunteers Intermediate Care Facilities for Individuals with Intellectual heard some patients are not allowing any visits (including at least 5% of patient care hours). Alternatively, Disabilities (ICFs/IIDs) (CMS) and our providers are concerned about meeting hospice providers may continue to utilize volunteers in other the 5% of patient care hours for volunteers during non-direct care activities (e.g. administration activities) and the PHE. consider using the flexibilities allowing for use of telecommunications technologies to further facilitate ways in which volunteers can continue to support the patients served, however, this is not required during the COVID-19 PHE. How should hospice programs monitor or restrict Please refer to the CDC guidance for exposures that might June 11, 2020 health care staff or hospice volunteers? warrant restricting asymptomatic healthcare personnel or Coronavirus 19 Disease (COVID-19) CMS Frequently Asked volunteers from reporting to work Questions for Non-Long-Term Care Facilities and