The Center for Medicare and Medicaid Services (CMS) has issued the final rule for the Home Health Conditions of Participation (CoP), which will be effective on July 13, 2017. The CoPs are the minimum standards that Home Health Agencies (HHA) must meet to participate in the Medicare program. Failure to do so can result in sanctions and potential program termination. The new CoPs are aimed at improving the quality of care for Medicare and Medicaid beneficiaries and are an integral part of CMS' focus on integrated, patient-centered care and outcome-oriented processes, with less emphasis on unnecessary administrative procedures.
The new CoPs are the first major revision in 30 years and have removed, added, and rearranged the standards. Requirements for the 60-day physician summary, professional advisory council, and quarterly record review have been eliminated and replaced with the new conditions requiring Quality Assessment and Performance Improvement (QAPI) and infection control programs. In addition, the standards were regrouped into three sections: General Provisions, Patient Care, and Organizational Environment.
General Provisions
This section describes the basis and scope of the conditions and provides definitions for terminology introduced in the new standards. An example is the definition of a branch that stresses oversight by the parent organization instead of geographical distances between the parent and the branch.
Patient Care
CMS' emphasis on patient rights and integrated patient care is the underlying directive in this section. Some conditions/standards required major revisions but no revisions were made for others.
Summary of Changes
Number |
Condition |
Changes |
|
484.40 |
Release of OASIS Information |
No changes |
|
484.45 |
Reporting OASIS Information |
No significant changes |
|
484.50 |
Patient Rights |
Provide patient with verbal notice of rights by second visit and written notice within 4 days of the evaluation visit Assess patient expectations of care and goals, anticipated risk/benefits, and factors that could impact treatment effectiveness Advise patient of specific federally-funded agencies as listed in the final rule Inform patient of agency transfer and discharge policies Complaint process is more specific regarding investigation of complain and complaint processing CMS has identified specific discharge and transfer reasons |
|
484.55 |
Comprehensive Assessment |
Assess patient strengths, goals ad care preferences “ROC on physician-ordered date” has been added to assessment |
|
484.60 |
Care Planning, Coordination, Quality of Care |
POC includes description of risk for ED visits and re-hospitalization and all necessary interventions to address risk factors POC includes patient/caregiver education for timely discharge POC includes patient’s Advance Directives Verbal orders include signature, date and time and are integrated into POC Communication with all physicians involved in the POC regarding changes in patient’s health status and discharge plans Integration of services Written instructions for patients to include visit schedule and frequency, patient medication schedule, any medications or treatments to be provided by HHA including therapy Name and contact information of HHA clinical manager provided to patient |
|
484.65 |
QAPI |
NEW - HHA must develop, implement, evaluate and maintain an effective, ongoing, HHA-wide, data-driven QAPI program |
|
484.70 |
Infection Prevention and Control |
NEW - HHA must maintain and document an infection control program |
|
484.75 |
Skilled Professional Services |
Combined all professional services but no changes |
|
484.80 |
Home Health Aide Services |
Aide to report changes in patient’s condition Required elements defined for supervision of Home Health Aide services |
Organizational Environment
The final section contains requirements related to organizational processes such as administration, personnel, and clinical records.
Number |
Condition |
Changes |
|
484.100 |
Compliance with Laws and Regulation |
HHA may not substitute its equipment for a patient’s equipment when assisting with self-administered tests. |
|
484.102 |
Emergency Preparedness |
Individualized emergency plan for patient |
|
484.105 |
Organization and Administration |
Governing body is responsible for overall management of agency including QAPI Clinical Manager is responsible for oversight of all patient care services and personnel Defines Parent-Branch relationship |
|
484.110 |
Clinical Records |
Contact information for patient and representative Contact information for PCP (or other) who will be responsible for care after discharge Completed discharge summary sent to PCP (or other) within 5 business days of patient’s discharge Completed transfer summary sent within 2 business days of a planned transfer if care is to continue at health care facility Completed transfer summary sent within 2 business days of becoming aware of unplanned transfer if patient still receiving care at health care facility Retrieval of clinical records (hard copy or electronic) must be made available to patient, free of charge, upon request at next home visit or within 4 business days (whichever comes first) |
|
484.115 |
Personnel Qualifications |
No significant changes |
A new Interpretive Guidelines and State Operations Manual based on the new Home Health CoPs are still under development. Once released, they will serve to further interpret and clarify the new CoPs.
How are you preparing for the new CoPs?