Home Health & Hospice Week

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Along with the six-month delay for Conditions of Participation implementation, Medicare also gives home health agencies an additional six months for its new quality assessment and performance improvement (QAPI) mandate.

“A phased-in implementation timeframe is appropriate for the requirement that HHAs conduct performance improvement projects because it will take additional time to collect the data necessary to identify areas for performance improvement,” the Centers for Medicare & Medicaid Services says in the July 10 Federal Register final rule confirming the six-month delay. “The additional phase-in period allows HHAs the time necessary to collect data prior to implementing performance improvement projects.”

When CMS set the overall CoP deadline for July 13, it set the QAPI deadline for Jan. 13, 2018. Now that the overall CoP deadline is pushed to Jan. 13, CMS also pushes the QAPI deadline back to July 13, 2018, according to the rule.

“Allowing HHAs until July 13, 2018 to implement performance improvement projects provides for a full 18 month period between the date that the final rule was published and the date that we would expect HHAs to initiate performance improvement activities,” CMS notes in the rule.

One commenter suggested pushing the QAPI deadline back even further, 18 months instead of just six. But CMS shoots down that idea. “To delay the entire QAPI requirement for 18 months beyond the effective date for the rest of the rule would not require HHAs to begin data collection until July 2019; HHAs would also need 6 months to collect data before initiating performance improvement activities in January 2020. We do not believe that waiting 3 full years to initiate performance improvement activities is in the best interest of patient safety, patient care efficacy, or patient care efficiency,” CMS says.

Many home health agencies already had a quality improvement program in place before CMS included the QAPI CoP. But for agencies that haven’t been doing this, the six-month delay is very helpful, says consultant Pam Warmack with Clinic Connections in Ruston, Louisiana. “Providers will definitely need this time to collect, analyze, and trend data to develop their structured QA plan as required in the new regulations,” Warmack says.

Agencies shouldn’t delay on their QAPI program in light of the delay, however. “Agencies do need to get started on the performance improvement process and data collection and analysis ASAP so they can determine appropriate PI projects that involve a year or more to be effective,” urges Judy Adams with Adams Home Care Consulting in Durham, North Carolina.

Also, keep in mind that “the QAPI projects may start on Jan. 13, 2018, but they won’t end on that date,” points out attorney Robert Markette Jr. with Hall Render in Indianapolis. “There will be an ongoing process of implementing the plan, collecting data, monitoring results, etc. Agencies should be prepared to start this process in January, but it may take months for a particular project to run its course.”