Home Health & Hospice Week

Proposed COP revisions contain more than just tweaks.

Leave space in your calendar for COP prep-aration next year.

On Oct. 6, the Centers for Medicare & Medicaid Services issued a proposed rule significantly revising the home health Conditions of Participation (see story, p. 274). If finalized, the new requirements will translate to new work for home health agencies in 2015.

One of the biggest changes will be to the quality assessment and performance improvement (QAPI) program, says attorney Robert Markette Jr. with Hall Render in Indianapolis. The “QAPI regulation is going to require agencies to really be on top of their QAPI efforts, especially in regards to documentation, planning, etc.,” Markette says.

“The addition of a strong QAPI requirement would not only stimulate the HHA to continuously monitor its performance and find opportunities for improvement, it would also afford the surveyor the ability to assess how effectively the provider was pursuing a continuous quality improvement agenda,” CMS says in the proposed rule.

The QAPI COP will have five parts, CMS says in the rule: (1) Program scope; (2) Program da-ta; (3) Program activities; (4) Performance improvement projects; and (5) Executive responsibilities.

Change: “Before, you could show the surveyor meeting minutes to show the group met, what was discussed, policies reviewed,” Markette tells Eli. “Now, you are going to need to show data — measures selected, measuring outcomes, plans to achieve goals, etc. Not to mention the governing body is going to have a role to play in this as well.”

“The current CoPs rely on a problem-oriented, external, after the fact (occurrence) approach to resolve patient care issues.” CMS notes in the rule. “The proposed QAPI CoP would require proactive performance monitoring through an effective, ongoing, agency-wide, data-driven QAPI program that is under the supervision of the home health agency governing body.”

Don’t expect to get a sympathetic ear from CMS if you complain that your small agency can’t handle a full QAPI program. 

“We believe small and mid-size HHAs would be able to effectively implement this condition as easily as larger HHAs,” CMS maintains in the rule. “The proposed QAPI CoP would provide HHAs with enough flexibility to implement the quality assessment and performance improvement process without inordinate expenditure of capital or human resources. An HHA could also use outside resources to assist in development and support of its QAPI program. Each HHA’s QAPI program should be individualized to reflect the size, scope, and complexity of its services and patient population.”

Bottom line: “We do not believe there is a need to differentiate our expectations for QAPI be-tween small-to-mid-size HHAs and larger HHAs,” CMS stresses in the rule published in the Oct. 9 Federal Register.

QAPI should be easier for HHAs that are accredited, believes consultant Lynda Laff with Laff Associates in Hilton Head Island, S.C. “QAPI really is not new to accredited agencies,” Laff tells Eli.