Effective January 13, 2018, CMS has released revised Conditions of Participation (CoPs) that home health agencies must meet in order to participate in the Medicare and Medicaid programs.
|On January 13, 2018, CMS released its final ruling updating the Conditions of Participation (CoPs) which govern the minimum health and safety requirements that HHAs must meet to participate in the Medicare and Medicaid programs. This was a delay from the initial date of July 13, 2017.|
|HHAs that fail to meet the new CoPs could face sanctions or potential program termination.|
|The new CoPs are aimed at improving the quality of care for Medicare and Medicaid beneficiaries. The rule is meant to improve the quality of healthcare services for all home health patients.|
- All Medicare- and Medicaid-certified home health agencies (HHAs)
Key Dates for the Revised Home Health Conditions of Participation
CMS released a final rule updating the home health Conditions of Participation
January 13, 2018
CMS implements the new HHA CoPs
January 13, 2018 – January 13, 2019
CMS has announced that in the first year of the new ruling, it will not impose any civil monetary penalties on agencies who are taking actions to be compliant, unless there is an identified Immediate Jeopardy situation*
Highlights from the final rule
Requirements for the 60-day physician summary, professional advisory council and quarterly record review have been eliminated and replaced with new conditions requiring Quality Assessment and Performance Improvement (QAPI), a strengthening of patient rights, and infection control programs.
- Patient Rights:
- Information for patients and their caregivers about the care being delivered must be understandable and conveyed in the individual’s primary or preferred language
- Patients and caregivers must receive education and training related to the specific patient’s care and treatment, including written instructions outlining medication schedule/instructions and details on the patient’s visit schedule
- Quality Assessment and Performance Improvement (QAPI) Program: Individualized QAPI programs need to be developed and implemented by HHAs to continually evaluate and show measurable improvement in indicators that will improve health outcomes, patient safety, and quality of care
- Infection Prevention and Control Program: HHAs are required to develop an infection prevention and control program that focuses on the use of standard infection control practices and patient/caregiver education and training. The program must include a method for identifying infectious and communicable disease problems and a results-oriented action plan
- Supervisory/Staffing Requirements: To help streamline care across various disciplines, HHAs must ensure that skilled professionals providing services (e.g. skilled nursing services, physical therapy, speech-language pathology services, occupational therapy, social work services) to HHA patients participate in the care coordination activities
Why are these changes happening?
The updated CoPs modernize the existing requirements to improve home health quality of care. The requirements have not undergone a comprehensive review in over 10 years.
Reflecting changes in the patient population and evolving care delivery models, the ruling contains major modifications in the HHA CoPs that parallel the finalized requirements for long-term care facilities, which were released in October 2016, demonstrating CMS’ commitment to coordinated, patient-centered care. According to CMS, “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 unnecessary procedural requirements.”
How should you prepare for this CoPs regulation?
Due to many of the rule’s more explicit requirements for the home health industry (e.g. patient notification and education) HHAs may need to shift personnel and resources and adapt their current practices to meet the requirements in this final rule.
- Develop your QAPI program: QAPI merges quality assurance (QA) and performance improvement (PI) in improve clinical quality and patient/resident quality of life. HHAs have flexibility when designing their QAPI programs, but CMS has also outlined key elements to include in QAPI, including recommended steps that can be used when making quality improvement plans
Additional Resources for Healthcare Providers
Visit CMS to learn more about this updated ruling on the Conditions of Participation for Home Health Agencies.