Home Health & Hospice Week

Board must approve Administrator backups, new CoPs say.

Under the incoming Conditions of Participation, you can’t be casual about who will fill in for the boss when she’s absent.

In the CoPs final rule, the Centers for Med-icare & Medicaid Services is serious about governing body approval of the home health agency Administrator — including anyone stepping in for the Administrator.

The governing body must authorize the designee who will act in the Administrator’s absence, CMS spells out in the rule. “Pre-designation needs to be by both the administrator and the governing body as a whole,” CMS clarifies.

“The time necessary to obtain governing body approval for the designation should be factored into the HHA’s timeframe as established in its policies and procedures. The goal of this requirement is to provide management continuity within the HHA to the greatest degree possible. HHA staff should know and be able to verbalize upon interview whom the predesignated individual(s) is/are for this role.”

One commenter suggested loosening up the requirement allowing “the governing body to approve the HHA’s policy outlining how administrative oversight will be transferred in the absence of the administrator.”

CMS doesn’t go for it. “The number of administrator designees should be determined by HHA needs and set forth in each HHA’s policies and procedures,” CMS responds in the rule. “The goal is to provide continuity within the HHA to the greatest degree possible,” the rule says. “We are retaining the requirement that the governing body must approve the predesignated individual(s).”