The home health care industry has not seen a change in Medicare’s Conditions of Participation (CoPs) in three decades. However, in January 2017, the Centers for Medicare & Medicaid Services (CMS) finalized new standards for improving the quality of health care services for home health patients and strengthening their rights. The changes in the home health CoPs will have serious implications for home health agencies (HHAs).
Home Health Services
Medicare’s home health benefit covers a range of services. Medical professionals from hospital CEOs and directors to administrators, quality managers and office and field staff must become familiar with the new CoPs – fast.
If your facility provides any of the following, according to the final rule, you are responsible for complying with the new CoPs:
- Part-time or intermittent skilled nursing care furnished by or under the supervision of a registered professional nurse
- Physical therapy, speech-language pathology, and occupational therapy
- Medical social services under the direction of a physician
- Part-time or intermittent home health aide services
- Medical supplies (other than drugs and biologicals) and durable medical equipment
- Services of interns and residents if the HHA is owned by or affiliated with a hospital that has an approved medical residency training program
- Services at hospitals, skilled nursing facilities, or rehabilitation centers when the services involve equipment too cumbersome to bring to the home
Final Rule CoPs
The final rule revises the CoPs that HHAs must meet in order to participate in the Medicare and Medicaid programs. The requirements focus on the care delivered to patients by HHAs, reflect an interdisciplinary view of patient care, allow HHAs greater flexibility in meeting quality care standards, and eliminate what CMS considers unnecessary procedural requirements.
These changes are wide-ranging and involve almost everything a home health agency provides or maintains:
- Organization and administrative services
- OASIS reporting and release of information
- Personnel qualifications
- Care planning and coordination of services
- Comprehensive assessment
- Skilled services
- Aide services
- Infection control
- QAPI
- Emergency preparedness
- Compliance with federal, state and local laws and regulations related to health and safety of patients
- Clinical records
In order to properly implement all the changes, you will need to:
- Integrate services among disciplines and physicians
- Assess the impact on the plan of care and updates to orders
- Understand how a good QAPI program can lessen your day-to-day challenges
- Analyze the proper data to develop or enhance your QAPI
- Be familiar with the guidelines for emergency preparedness and what your responsibilities are
How to Prepare
In the upcoming “Home Care CoPs Virtual Boot Camp 2017” with noted consultant and coding expert Sharon M. Litwin on Tuesday, October 31, 2017, she will discuss how significant the new CoPs are and how they will impact your agency’s day-to-day operations. This webinar will provide you the information you need to make sure you are in compliance with the changes. In four sessions, Sharon will provide an overview of what’s included in the home health CoP changes and the responses to the final rule that help to clarify the CoPs. She’ll also provide an update of how compliance is going in the first few months after the July 13 deadline.
