The Centers for Medicare & Medicaid Services (CMS) has released a draft of interpretive guidelines (Guidelines) to the Home Health agency Conditions of Participation (the COPs).  After having previously been delayed, the COPs are set to be implemented January 13, 2018.  While feedback is being solicited on the draft and final guidelines have yet to be released, agencies should begin preparing in the event that no further delay is provided.

While information is provided on all of the COPs, examples of the topics guidelines are provided for include OASIS, patient rights, assessments, care planning, coordination of services, quality of care, quality assessment and performance improvement, infection prevention and control, skilled professional services, home health aide services, compliance, emergency preparedness, functional capacity, clinical records and personnel qualifications.