Home Health & Hospice Week

Get started on education efforts right away.

The July 13 deadline for the new Conditions of Participation is rushing up at you. You have less than six months to make sure your governing board is ready. Take these steps now to prepare:

1. Fine tune your members. The Centers for Medicare & Medicaid Services does give agencies some leeway as to who should serve on the governing body. “An HHA may establish a governing body composed of individuals of its choosing,” the CoPs final rule explains. “The individuals that comprise the governing body are those who have the legal authority to assume responsibility for assuring that management and operation of the HHA is effective and operating within all legal bounds. Those individuals could be members of the previouslyrequired Professional Advisory Committee, but that is not a requirement.”

2. Formulate new P&Ps. For the QAPI CoP, “HHAs should begin to consider how they will connect their governing body to the QAPI process and document the governing body’s involvement,” law firm Hall Render says in its rule analysis. The same goes for the other CoP requirements.

3. Educate. “Agencies have six months to begin educating their governing body on the changes and new processes to involve the governing body,” warns Hall Render attorney Robert Markette, Jr. Don’t waste a minute.

4. Document. It’s not enough to set up the new processes and perform them. “Agencies will need to … document, document, document the process,” Markette stresses.

Do this: That documentation effort should “include the use of dashboards to report on QAPI efforts, suggestions from the QAPI program to the board for future projects, reports of identified waste or fraud to the board and similar matters,” Hall Render suggests. “The governing body’s minutes/agenda ought to include, at least annually, a QAPI discussion and related decision-making,” it adds.