The Centers for Medicare & Medicaid Services (CMS) is proposing to delay the effective date for the revised Conditions of Participation (CoPs) for Home Health Agencies (HHAs).  The original effective date was July 13, 2017.  The proposed delay would extend the effective date for an additional six months, until January 13, 2018.  In a previously published post, we discussed the HHA CoPs.

CMS proposes to make two additional date changes in order to conform with the new effective date:

  • A new phase-in date for the Performance Improvement Projects standard at 42 CFR 484.65(d) of July 13, 2018, allowing an additional six months to collect data before implementing data-driven performance improvement projects.
  • A revised date for the grandfathering provisions in the Standard: Administrator, home health agency at 42 CFR 484.115(a).  As now proposed, administrators employed by a HHA prior to January 13, 2018, would not have to meet the new personnel requirements for administrators (including, among other requirements, that they be a licensed physician, a registered nurse, or hold an undergraduate degree).

The proposed delays follow concern voiced by a large number of HHAs that CMS had not provided enough time to implement the CoPs.