On Wednesday, February 14, the Agency for Health Care Administration (AHCA) announced an extension of the mandated data collection on nurses providing pediatric Private Duty Nursing (PDN) in the state. This decision follows AHCA's issuance of a Medicaid provider alert on February 7, a development actively advocated for by HCAF.

The updated deadline for submitting nurse information for PDN services is now March 1. Home health agencies are mandated to furnish details for each registered nurse (RN) or licensed practical nurse (LPN) available to provide, or currently providing, PDN to Florida Medicaid recipients under the age of 21. Moreover, independent RNs and LPNs are required to report their availability and service counties. The alert provides hyperlinks to surveys facilitating this data collection.

This data collection initiative originates from a court-ordered injunction issued on July 14, 2023, in response to a federal lawsuit alleging violations of the Americans with Disabilities Act. Providers with inquiries should direct their emails to AHCA at PDN_NurseSurvey@ahca.myflorida.com.

In response to the extension request, HCAF submitted several inquiries to AHCA concerning the report's purpose, duration, and scope. Please find the following updates:

• Alternate Reporting Option: AHCA has provided an Excel spreadsheet template as an alternative to the online form. Home health agencies may choose to use this template and must submit it to PDN_NurseSurvey@ahca.myflorida.com by 5:00 PM ET on March 1. Click here to download the template.
• Reporting for Multiple Licenses: If using the Excel template, multiple home health agency locations (multiple provider IDs) can be reported on the same spreadsheet provided that all required data elements are accurately completed. It is crucial to ensure that the hours each nurse is available to work and provide PDN are precisely allocated across each home health agency location.
• Duplication: AHCA assures providers that the survey is designed to control for nurses who work for multiple agencies, thereby preventing duplication in reports.
• Duration: AHCA intends to collect this data quarterly, as stated in the provider alert. While the federal court anticipates a term of 24 months for the requirements outlined in the Order of Injunction referenced in the provider alert, AHCA will request this information quarterly from home health agencies, independent RNs, and independent LPNs until further notice.
• Public Records: In addressing HCAF's concerns regarding potential public records requests and the disclosure of providers' proprietary recruitment and retention strategies, AHCA clarified its intention to utilize the reported information solely for the assessment of nursing capacity and workforce availability to deliver PDN to Florida Medicaid recipients under 21 years of age. Additionally, AHCA emphasized that these reports will be submitted to the United States District Court for the Southern District of Florida, which issued the Order of Injunction referenced in the provider alert.

AHCA expressed openness to reviewing process improvement proposals from stakeholders, including HCAF and targeted providers, for future reporting.

As your advocate, HCAF encourages member feedback to inform our advocacy efforts with AHCA. Please direct any concerns to Kyle Simon, Senior Director of Policy, Advocacy & Communications, at ksimon@homecarefla.org.