Home Health & Hospice Week

Aides’ med administration, verbal order clarifications welcome.

While there is a lot to be worried about in the newly released final Interpretive Guidelines for the Home Health Conditions of Participation, there are some revisions to welcome, too.

Check out these IG areas that could make your life easier:

• Aides & meds. The Centers for Medicare & Medicaid Services has made a change for the better in the guidelines for 484.80(g)(3) The duties of a home health aide include … (iv) Assistance in administering medications ordinarily self-administered, highlights attorney Robert Markette Jr. with Hall Render in Indianapolis.

Old: The draft IGs said, “Self-administration of medications means that the patient (or the patient’s caregiver) is able to manage all aspects of taking her or his medication, including safe medication storage, removing the correct dose of medication from the container, taking the medication at the correct time, and knowing how to contact the pharmacy for refills or other questions. Assistance in administering medications in this requirement means that the HH Aide may take only a passive role in this activity. This assistance is limited to getting water or fluids for the patient to take their medication.”

New: Now the final IGs say “‘Self-administration of medications’ means that the patient (or the patient’s caregiver, if applicable) is able to manage all aspects of taking her or his medication, including safe medication storage, removing the correct dose of medication from the container, taking the medication at the correct time, and knowing how to contact the pharmacy for refills or other questions. ‘Assistance in administering medications,’ as referenced in this requirement, means that the HH aide may take only a passive role in this activity. Assistance may include items such as:

• Bringing a medication to the patient either in a pill organizer or a medication container as requested by the patient or caregiver;
• Providing fluids to take with the medication;
• Reminding the patient to take a medication;
• Applying a topical product, such as a nonprescription cream, to intact skin per home health aide instructions in how to apply it.”

This clarification, while not modified as far as HHAs would like, is a very welcome change, Markette judges. “It’s much better than it was,” he tells Eli. “CMS deserves credit.”

Under the new IGs, aides can do things like open pill bottles for arthritis patients, hand patients their medication organizers, remind patients to take their meds, and apply non-prescription creams, he points out. This is especially important for agencies that serve Medicaid patients in extended care programs, he adds.

• Verbal orders & Plan of Care. For §484.60(a)(3) All patient care orders, including verbal orders, must be recorded in the plan of care, the draft IGs contained no additional guidance.

Now in the final IGs, CMS adds this elaboration under tag G576: “All patient care orders, including verbal orders are part of the plan of care. The plan should be revised to reflect any verbal order received during the 60 day certification period so that all HHA staff are working from a current plan. It is not necessary for the physician to sign an updated plan of care until the patient is recertified to continue care and the plan of care is updated to reflect all current ongoing orders including any verbal orders received during the 60 day period.

“Note: Pulse oximetry is a ubiquitous assessment tool, often used as a part of routine vital signs across health care providers,” the new IG says.

“I am grateful for the additional guidance, as there were some questions regarding what was meant by ‘must be recorded in the plan of care,’” notes consultant Pam Warmack with Clinic Connections in Ruston, Louisiana. “We didn’t know the timeframe they were expecting for that to happen. New guidance is appreciated.”