Home Health & Hospice Week

Navigate tricky transition period or face penalties.

In addition to just planning for Home Health Conditions of Participation changes, home health agencies may be able to go ahead and implement some of the revisions.

For example: The new CoPs require HHAs to document not only the date on which verbal orders are received from physicians, but the time as well, points out attorney Robert Markette Jr. with Hall Render in Indianapolis. Go ahead and get clinicians in the habit of recording the time now so that it is just routine by the time the CoPs actually take effect. “You have eight months to hammer staff on getting the signature, date and time,” he stresses. “It will serve you well come Jan. 13.”

HHAs can also implement many of the Patient Rights requirements now, adds Lisa Selman-

Holman with Selman-Holman & Associates and CoDR — Coding Done Right in Denton, Texas.

But be careful not to make changes ahead of the implementation date that put you out of compliance with the current CoPs, Selman-Holman warns. You “cannot stop complying with requirements that are effective now.”

For example: “I would love to stop the whole ‘group of professional personnel’ and ‘annual evaluation’ pieces, but then I would be out of compliance with the current regulations,” Selman-Holman illustrates.

You never know: While this new implementation date seems firm, never count out another delay, says attorney Bob Morgan with Much Shelist in Chicago. “With the new [Trump] administration, rulemaking could undergo more delays than usual, so this 6-month delay could become a 2-year delay,” for example, Morgan says. “Even under the prior Obama administration, with an HHS Secretary generally inclined to propose and finalize rulemaking in a prompt manner, rules often took years for implementation.”

Nevertheless, it “would certainly be prudent to begin preparing for compliance with the new Conditions of Participation” now, Morgan notes.