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State Issues DAL Requiring Updated HCS Roles for Home Care and Hospice Providers

The Department of Health (DOH) issued a Dear Administrator Letter (DAL) on June 2, 2022 regarding certain roles that home care and hospice providers are required to assign and provide contact information for in the Health Commerce System (HCS) to ensure proper communication and coverage in urgent and emergency situations. The HCS roles must be updated within three weeks of June 2nd. The HCS guidance is similar to that recently issued for long term care facilities.

As noted in the guidance, the HCS is the primary mechanism that DOH uses to communicate with licensed home care services agencies (LHCSAs), certified home health agencies (CHHAs), long term home health care programs (LTHHCPs), and hospice providers in New York State. The HCS is used for a multitude of purposes, including, but not limited to, targeted communications, access to applications, and collecting cost and statistical information from providers.

In emergency situations, it is imperative that the Department is able to communicate directly, whenever necessary, on urgent matters with the specific individuals holding leadership positions within the agency. To that end, the Department reminds agencies of their regulatory responsibility to maintain up-to-date business and after-hours contact information for the agency leadership roles in the HCS Communications Directory. The DAL describes steps to be taken by your agency to help ensure that the Department has this capability.

The new guidance requires certain roles to be updated on a regular basis and as needed when personnel changes occur. In the guidance and attached table, please review primary and backup roles, the text describing each role, and how many people should be assigned to each. One single individual should be assigned to each primary leadership role (e.g., “Administrator”), and one or two individuals can be assigned to the new backup role. The new backup roles will receive the same communications as the primary roles and will have the same access to the HCS applications that the primary role has.

Please ensure that your agency’s HCS Coordinator modifies the contact information for these roles in the Directory accordingly within three weeks of the date of the DAL (June 2nd). To reiterate, going forward, only the one person meeting the primary leadership role description should be assigned to each of the primary leadership roles listed in the attached table. Any additional individuals currently assigned to that primary leadership role should be removed. One or two additional individuals can be assigned to the new backup role. All phone, email, and text contact options must be completed with up-to-date information for both business hours and after-hours options. After-hours contacts must include cell phone numbers. Agency leadership should verify that the information entered for the Directory roles by their HCS Coordinator is correct.

After the due date, Department staff will review the Directory to ensure that role assignments have been made/updated and will contact those agencies that have not completed their updates. Drills of this contact information will be conducted periodically to ensure maintenance and accuracy of this information. Those with HCS roles should access the site regularly and ensure assignment of the numerous required roles.

Please review the guidance carefully. The Department will continually monitor these role assignments. A Statement of Deficiencies may be issued to agencies that do not meet all of the requirements set out in the DAL, and subsequent enforcement action may be taken for findings of noncompliance.

If you have any questions about these requirements or need assistance with assigning HCS roles, please call 518-408-1638 or send an email to hcreg@health.ny.gov.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871