Home Health & Hospice Week

These notices must go to existing patients too.

In addition to overarching activities you must undertake for CoP preparation, ranging from writing new P&Ps to educating staff to auditing, you also should drill down to the specifics of the new requirements to ensure you don't run afoul of your surveyor next time she visits.

Preparing for the new and revised Home Health Conditions of Participation is a daunting task that you are likely already in the middle of, but heeding this advice from industry experts can help you direct your compliance efforts to get the most bang for your prep buck:

For Patient Rights: "Prioritize the Patient Rights updates and consider providing scripting to help clinicians hit key points with patients," recommends consultant Cindy Krafft with Kornetti & Krafft Healthcare Solutions.

"Agencies must be certain that their intake forms, (patient rights, care plan summary, etc.) are all ready to go and that staff are familiar with the process," advises attorney Robert Markette Jr. with Hall Render in Indianapolis. "Surveyors are likely going to focus on auditing for Patient Rights issues, which is why I would be focusing on those issues in the final weeks."

Also, "agencies need to remember that the CoPs apply to all patients, so new Rights and Responsibilities [notices] will need to be delivered to current patients," Haydel says.

For Emergency Preparedness: "The CoPs expect that all staff will know what to do in emergencies," and you can bet surveyors will ask them, warns Julianne Haydel with Haydel Consulting Services and The Coders in Baton Rouge, Louisiana. The same goes for Patient Rights. Be sure your training emphasizes these areas.

For QAPI: "Hopefully [agencies] have already set the QAPI process in motion," says consultant Anna Doyle with Laff Associates.

HHAs that don't yet have a QAPI program must "get it developed and implemented and start auditing now," stresses Sharon Litwin with 5 Star Consultants in Camdenton, Missouri. 5 Star is currently helping many clients who need a quick QAPI ramp-up, Litwin reports.

It "starts with a CASPER analysis to identify quality indicators," she explains. Agencies "then add more quality indicators from their services - i.e., IV, wounds, billing, etc."

After agencies ensure that they have selected appropriate and measurable indicators for monitoring, "staff needs to be educated and re-educated about what important selected processes and functions will be monitored," Doyle recommends.

Your QAPI compliance success will depend on how you set up the program, Doyle says. "There needs to be a focus on teaching the entire agency about QAPI and delegating responsibility for components of their program to many individuals," she urges. Providers also must select "a manager for implementation and follow up," she adds.

For Infection Control: Don't fret if you haven't gotten your IC program down pat yet. 5 Star is also helping many agencies implement an IC program  quickly (as well as EP), Litwin says. But you need to nail it down ASAP.

"Simplify instead of complicate what is in place," Haydel says of your potentially outdated IC plan. "Put your real efforts into preventing and monitoring infections and let your computer do the data collection."

Your IC plan "should be available and have clear instructions for anyone with a question," Haydel says on The Coders blog. "The number of pages your plan has irrelevant. The effectiveness of the program is where you should focus your efforts."

For Care Planning: "Agencies will need to review their internal documentation processes for Care Planning to ensure that all requirements of 484.60 are met," Doyle emphasizes.

For Care Coordination: Your staff will perform better in surveys if they see the whole picture.

"Remind staff there is great value in bringing the patient and the caregiver into the care coordination effort, and integrate that into your documentation regarding discussion about the plan of care," recommends consultant Karen Vance with BKD. "Reinforce with clinicians how it is better care, rather than just meeting a regulation," Vance says.