Home Health & Hospice Week

Follow this expert advice to make sure your drop sites are on the up-and-up:

1. Check with the state. Drop sites are only OK if your state and local laws and regulations permit them, the Centers for Medicare & Medicaid Services says in its Nov. 12 memo to surveyors. "Providers should be careful to review state requirements prior to jumping into the provision of drop sites," counsels Chicago, IL-based consultant Rebecca Friedman Zuber.

2. Get written permission. Some states don't address drop sites at all in their licensure rules, Zuber notes. In those cases, "providers should look for a written assurance that they are acceptable in the opinion of the licensing agency," she advises.

3. Follow the new guidelines. Now that CMS has spelled out what is prohibited at a drop site, be sure you're toeing the line, experts urge (see story, this cv page).

4. Adjust policies and procedures. Now is the time to dust off your P&Ps on drop sites and revamp them in light of the new guidelines, recommends consultant Judy Adams with Charlotte, NC-based LarsonAllen Health Care Group. If you never spelled out drop site rules in your policies, do it now, she advises.

5. Be prepared for inspection. Drop sites aren't subject to routine surveys, CMS admits in the memo. But "they may be subject to state or [regional office] inspection at any time," the agency warns.