As any healthcare provider involved with the Centers for Medicare and Medicaid Services knows, following CMS directives is critical. That makes it all the more stressful when new rules are introduced or guidelines change. Such is the case with the new Home Health Agency Conditions of Participation (CoPs) that rolled out this year.

As of January 13, 2018, home health agencies have a new set of rules to follow. Initially slated for a 2017 implementation, CMS delayed the enactment as they tweaked the new CoPs to get them to their final stage, which is now applicable to all home health care agencies. CMS mandates can be confusing enough to begin with, but the new CoPs make this year especially challenging for home health agencies.

What are Conditions of Participation?

Conditions of participation are health and safety standards that any healthcare provider must abide by in order to be part of CMS. In other words, providers must follow the CoPs in order to be eligible for Medicare reimbursement. Each health entity has different CoPs that they must follow. For example, home health agencies have different conditions of participation than hospitals. And, the rules are subject to change at any time (with notice, of course). This means providers that wish to receive reimbursement from CMS must be sure to stay on top of all of the CoPs and any changes that the organization makes the the CoPs. Providers must be sure to fully understand and implement changes outlined in new CMS rules, as failure to meet even one of the CoPs can result in exclusion from the Medicare program if the failure is not remedied.

Home Health Agency Conditions of Participation

This year, home health agencies are subject to new conditions of participation. The changes came into effect in January 2018, so HHAs must make sure they fully understand and abide by these new CoPs in order to receive their deserved reimbursement for the coming fiscal year. Certain proposed changes, such as a major slashing of the home health agency reimbursement budget, did not come to fruition in the final rule. But, there are other changes that any home health agency owner or employee must be aware of. Of course, the new rules are not without purpose. They are designed with patient safety and quality of care in mind. Despite the good intentions, new conditions of participation can still be a headache for anyone involved in healthcare.

What Are Some of the Changes to Home Health Agency CoPs?

Care Plan Requirements

CMS made changes regarding the process by which patients are assessed by home health care providers. In the past, home health nurses would conduct a patient assessment, discuss the assessment and develop a care plan with a physician, and the process could be considered done. Now, every patient will be evaluated using a comprehensive patient assessment which must be continually updated at regular intervals or any time there is a meaningful change in the patient’s condition. The care plan based on that assessment will continually update and modify as well. This can lead to better care management, as the assessment will track all of the changes and progression of a person’s condition.

Quality Assessment and Performance Improvement (QAPI) Program

The QAPI program is a new quality improvement initiative for home health agencies It requires that all home health agencies measure and track quality indicators, such as adverse patient events. The frequency and detail of this data collection needs to be approved by the HHA’s governing body in order to be considered in line with the new conditions of participation. CMS outlined specific requirements for the home health agency’s quality improvement activities as well. While it can be burdensome for agencies to adopt this new method of rigorous data collection, quality assessment and improvement programs ultimately provide patients with higher quality care- a goal any health care provider should be happy to get behind.

Integrated Communication System

CMS is requiring all home health agencies to have an integrated communication system that facilitates more coordinated care. The new CoP rule requires all home health agencies to have a system in place to communicate any changes in a patient’s care plan to not only the patient, but also their family, primary care doctor, and any other physicians involved with their care. Once again, this measure can improve quality of care as increased collaboration between members of a patient’s care team across different disciplines can lead to better overall care and outcomes.

Infection Prevention and Control

The previous home health CoPs briefly mentioned infection prevention and control, but did not provide any specific guidelines. The new conditions of participation outline more detailed measures that home health agencies must abide by. The rule includes prevention, control, and education measures. As part of the CoP, home health agencies must maintain a plan for infection prevention and control measures and document their actions that show they are adhering to the guidelines. The HHA’s infection control plan must include both a method for identifying infectious disease problems, and actions to improve disease prevention and prevent the spreading of the diseases.

How Do the New CoPs Affect Home Health Agencies?

The new CoPs require that home health care providers more frequently update documentation such as a patients’ care plans and more diligently track measures like quality improvement and infection prevention. If an agency was still using a paper-based system for documentation, they will certainly need to update and switch to an electronic system to meet the new conditions of participation. While these new conditions will likely spur positive change in patient outcomes, it does mean more effort and time will need to go into these activities. Staff should devote time to training and education to ensure that all new requirements are met, or agencies risk losing out on reimbursement. HHAs should consider employing the help of a specialized billing and accounting firm to help them manage financial aspects of the agency while they focus on these changes. The new CoPs are very important, but so are other business responsibilities like billing, cost management, and Medicare Cost Reports. Consulting and accounting firms like Liberty can help HHAs stay on top of their finances so that management does not get too bogged down. Making the necessary changes to fit the new CoPs may make the coming months a rough patch for HHAs, but working with a billing and accounting firm gives them one less thing to worry about this year.

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