Home Health & Hospice Week

Conditions of Participation:

Don't Forget: You Must Issue This Info To Patients, Too

You’ll hand out clinical manager contact details.

The new Patient Rights Condition of Participation isn’t the only new provision requiring you to give information to patients.

Under §484.60 Condition of participation: Care planning, coordination of services, and quality of care, there are more requirements on communicating with the patient, points out Sharon Litwin with 5 Star Consultants in Camdenton, Mo.

According to the CoPs final rule in the April 3 Federal Register, §484.60(e) says “Standard: Written information to the patient. The HHA must provide the patient and caregiver with a copy of written instructions outlining:

(1) Visit schedule, including frequency of visits by HHA personnel and personnel acting on behalf of the HHA.
(2) Patient medication schedule/instructions, including: medication name, dosage and frequency and which medications will be administered by HHA personnel and personnel acting on behalf of the HHA.

(3) Any treatments to be administered by HHA personnel and personnel acting on behalf of the HHA, including therapy services.
(4) Any other pertinent instruction related to the patient’s care and treatments that the HHA will provide, specific to the patient’s care needs.
(5) Name and contact information of the HHA clinical manager.”

But at least the Centers for Medicare & Medicaid Services nixed its proposal to have HHAs give the Plan of Care directly to patients, notes consultant Pam Warmack with Clinic Connections in Ruston, La.

Commenters on the proposed rule offered many good reasons to eliminate the POC requirement, CMS notes in the final rule, including patients’ inability to understand technical medical jargon and the inadvisability of leaving sensitive medical information in the patients’ home.

Plus: Under Clinical Records CoP §484.110 (a)(6), HHAs must send discharge summaries within five days and transfer summaries within two days (see Eli’s HCW, Vol. XXVI, No. 5). While this information will go to other healthcare providers instead of to patients directly, the summaries will represent a significant new communication burden.

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