Home Health & Hospice Week

Expect finalization of the COPs next year.

The first changes to the home health COPs in 25 years may mean some big differences in how you operate.

Overview: “The regulation, as proposed, creates a framework for innovation and flexibility by adding requirements that are able to be adapted to the needs of individual home health agencies over an extended period of time,” the Centers for Medicare & Medicaid Services says in its fact sheet about the Conditions of Participation proposed rule released Oct. 6. “The proposal also addresses the use of current patient care and home health agency management practices, most notably by incorporating agency-identified patient measures into both the care planning and quality processes.”

Be prepared for these changes to the COPs, CMS says in its fact sheet about the rule published in the Oct. 9 Federal Register:

• HHAs must develop, implement, and maintain an agency-wide, data-driven quality as-sessment and performance improvement (QAPI) pro-gram. The QAPI requirement mirrors activity al-ready taking place in the industry’s move towards a prospective quality of care approach that focuses on preemptive planning that continuously addresses quality improvement. It would be based on data already collected in the OASIS process, CMS-provided patient outcome and process reports, and numerous other industry efforts currently underway.

• Expansion of the current patient rights requirements to clarify the rights of each patient, the process for conducting patient rights violation investigations, and the process for addressing verified violations.

• Focusing of the patient assessment requirement on each patient’s physical, mental, emotional, and psychosocial condition.

• HHAs must maintain a system of communication and integration to identify patient needs, coordinate care provided by all disciplines, and effectively communicate with physicians. This requirement would formalize and shape current, informal communication and coordination structures within HHAs to assure that patients receive the right care from the right discipline at the right time, with the ultimate goal of improving patient care outcomes and efficiency.

• A new infection control requirement that reflects current health care practices. It would require each HHA to maintain and document a program to prevent and control infections and communicable diseases. The infection control program would follow accepted standards of practice, including standard precautions, and educate staff, patients, and caregivers about proper infection control procedures.

• Merger of the requirements for nursing and therapy services into a single requirement that focuses on integrated patient care planning and delivery, assuring appropriate supervision of all services.

• Reinforcement of the current home health aide supervision requirements by requiring additional supervision and training when an agency suspects that home health aide skills are insufficient.

• Clarification of the management and administrative structure of HHAs by allowing the administrator to designate an individual to act in his/her absence, which may be the skilled professional that is available during all operating hours.

• Elimination of “subunits.” Designating an HHA location as a “subunit” is a vestige of the old HHA payment system. Under the current payment system, having HHA “subunits” is no longer necessary. This change allows parent agencies to have greater control over all of their offices by placing all locations under the leadership and direct management control of the parent agency. The process for requesting the addition of a branch office would remain unchanged.

• Revisions to OASIS requirements to up-date applicable electronic data transmissions to meet current federal standards.