Home Health & Hospice Week

Conditions of Participation:

Examine Your Governing Body's New Responsibilities

The new CoPs will add a lot more to the plate.

New governing body duties are sprinkled throughout the final Conditions of Participation. Take a look at the rules they’ll need to live by when the summer implementation date arrives:

§ 484.105 Condition of participation: Organization and administration of services.

(a) Standard: Governing body. A governing body (or designated persons so functioning) must assume full legal authority and responsibility for the agency’s overall management and operation, the provision of all home health services, fiscal operations, review of the agency’s budget and its operational plans, and its quality assessment and performance improvement program.

(b) Standard: Administrator.
           (1) The administrator must:
                    (i) Be appointed by and report to the governing body;


(h) Standard: Institutional planning. The HHA, under the direction of the governing body, prepares an overall plan and a budget that includes an annual operating budget and capital expenditure plan.


(3) Preparation of plan and budget. The overall plan and budget is prepared under the direction of the governing body of the HHA by a committee consisting of representatives of the governing body, the administrative staff, and the medical staff (if any) of the HHA.

(4) Annual review of plan and budget. The overall plan and budget is reviewed and updated at least annually by the committee referred to in paragraph (i)(3) of this section under the direction of the governing body of the HHA.

§ 484.65 Condition of participation: Quality assessment and performance improvement (QAPI). The HHAmust develop, implement, evaluate, and maintain an effective, ongoing, HHA-wide, data-driven QAPI program. The HHA’s governing body must ensure that the program reflects the complexity of its organization and services; involves all HHA services (including those services provided under contract or arrangement); focuses on indicators related to improved outcomes, including the use of emergent care services, hospital admissions and re-admissions; and takes actions that address the HHA’s performance across the spectrum of care, including the prevention and reduction of medical errors. The HHA must maintain documentary evidence of its QAPI program and be able to demonstrate its operation to CMS.
(a) Standard: Program scope.


(3) The frequency and detail of the data collection must be approved by the HHA’s governing body.

The Centers for Medicare & Medicaid Services also will require that “any existing subunits, which already operate under their own provider number, will be considered distinct HHAs and will be required to independently meet all CoPs, including having an independent governing body and administrator,” the final rule says.

Source: Jan. 13 Federal Register, Final Rule: Conditions of Participation for Home Health Agencies.

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