Home Health & Hospice Week

Use the final rule for compliance clues.

You may be frustrated that you have to wait until December for the final Interpretive Guidelines for the new home health Conditions of Participation, but don’t let that hamper your CoP readiness efforts.

“Do not wait,” exclaims Sharon Litwin with 5 Star Consultants in Camdenton, Missouri. As the Centers for Medicare & Medicaid Services makes clear in its delay final rule, agencies must be compliant by Jan. 13 whether the Interpretive Guidelines are out or not (see story, p. 194).

“Agencies should not delay their preparations until the Interpretive Guidelines are published,” agrees consultant Pam Warmack with Clinic Connections in Ruston, Louisiana. For one thing, “the month of December is always a difficult month in home care because of the Christmas holiday season,” Warmack points out.

Plus, “we have no guarantee that CMS will be timely and actually publish the Guidelines in

December as promised,” Warmack adds.

Bottom line: “Providers should use the entire six months available,” Warmack emphasizes.

Ideally, you should already be well on your way to CoP compliance, since the CoP final rule was published in January. The purpose of the delay from July 2017 to January 2018 “was to give agencies more time to comply,” points out attorney Robert Markette Jr. with Hall Render in Indianapolis. “Hopefully they used it.” Otherwise, you’re in the same boat as you were before CMS granted the six-month delay.

But even if you haven’t prioritized CoP readiness, now is the time to get started. Do not use the Interpretive Guidelines as an excuse to put it off, experts stress.

Pointer: While the Guidelines aren’t out yet, you can still use CMS’s responses to comments in the CoPs final rule to help inform your preparation, Litwin recommends.