On January 13, 2017, the Centers for Medicare and Medicaid Services (CMS) published a Final Rule updating the home health agency (HHA) Conditions of Participation (CoPs). HHAs only have until July 13, 2017 to implement these extensive changes. CMS revised the CoPs to focus on a “patient-centered, data-driven, outcome-oriented process that promotes high quality patient care at all times for all patients.”
Below are some of the most significant changes to the CoPs for home health agencies (HHAs) — the Final Rule:
- Revises the Patient Rights CoP to include a list of information HHAs must provide patients and their representatives and how such information must be communicated. For example, a HHA must notify patients and their representatives of its policies governing admission, transfer, and discharge prior to receiving care from the HHA. This standard contains criteria outlining when and how HHAs can discharge or transfer a patient.
- Imposes a requirement that HHAs compile a discharge or transfer summary that includes: (1) a summary of the patient’s stay, (2) the current plan of care, and (3) any other documentation that will assist in post-discharge or transfer continuity of care.
- Formalizes the content that must be included in a comprehensive patient assessment, and adds several requirements, such as an evaluation of the patient’s psychosocial, functional, and cognitive status and an assessment of the patient’s progress toward his or her goals. CMS believes this revised standard will provide a more holistic view of the patient’s overall health.
- Creates a new “care planning, coordination of services, and quality of care” CoP, under which HHAs must provide individualized patient care plans addressing the needs identified in the comprehensive assessments. Among other things, this requires HHAs to provide written instructions to the patient and his or her care giver regarding future visit schedule, medication schedule and instruction, and other patient care instructions.
- Creates a new “quality assessment and performance improvement” (QAPI) CoP. This CoP requires each HHA to establish a data-driven, HHA-wide quality improvement program designed to improve outcomes, patient safety and care quality.
- Removes the requirement to provide each patient’s attending physician a written report at least every 60 days.
- Requires skilled professionals (such as registered nurses) to supervise skilled professional assistants (such as licensed practical nurses).
- Creates a new “clinical manager” role, responsible for providing oversight of all of an HHA’s patient care services and personnel. The clinical manager must be a licensed physician, physical therapist, speech-language pathologist, occupational therapist, audiologist, social worker or registered nurse.
- Requires administrators to be responsible for the day to day operations of the HHA.
- Requires an HHA’s governing body to assume legal authority and responsibility for the HHA’s overall management and operation, including its QAPI program.