Home Health & Hospice Week

Is your Infection Control Plan from this decade?

Home health agencies may feel overwhelmed by the volume of new and revised Conditions of Participation that Medicare will implement Jan. 13. But they can expect surveyors to zero in on these hot topics when they come knocking:

Patient Rights

"Given the focus in the CoPs and the draft guidance," Patient Rights seems to be an area "that will be extremely important," expects attorney Robert Markette Jr. with Hall Render in Indianapolis. "The emphasis on Patient Rights will also lead to a focus on accessibility and LEP issues."

Adding to agencies' survey woes is the fact that the Patient Rights section is likely to "prove to be most troublesome, because it is significantly different" than the current CoPs, Markette says. The need to identify a legal representative versus a patient-selected rep, the patient care summary "that explains the care, but cannot be the 485," the issues related to accessibility, and more "will create lots of areas for mistakes and 'interpretation,'" Markette forecasts. (See more on patient rights and LEP topics in Eli's HCW, Vol. XXVI, Nos. 15 and 16.)

Surveyors won't just be looking at your P&Ps or talking to staff about Patient Rights issues, cautions Julianne Haydel with Haydel Consulting Services and The Coders in Baton Rouge, Louisiana. "Expect surveyors to question patients on home visits about Patient Rights" as well, Haydel says.

QAPI

Surveyors are also likely to focus on agencies'Quality Assurance and Performance Improvement CoP requirements, Markette predicts.

QAPI may trip up some agencies "due to the issues of board involvement and the need to document the process in an objective fashion," Markette believes. "The lack of guidance from CMS on certain aspects of QAPI, such as what will they expect to see when an agency utilizes a non-OASIS measure (to justify the measure's appropriateness)," will also be a compliance pitfall.

Problem: Up until now, "many agencies have considered QAPI a burden and not a necessity," says consultant Anna Doyle with Laff Associates in Hilton Head Island, South Carolina. "For many reasons, agencies have placed quality on the back burner and assigned responsibility for implementing a quality program to an already overburdened clinical supervisor." And the programs they have implemented often don't live up to the new requirements (see story, p. 346)," Doyle adds.

Timeline: "QAPI will likely become a bigger survey issue in the summer, because that is when performance improvement programs are required," Markette points out.

Emergency Preparedness Plan

"The toughest requirement seems to be emergency preparedness," judges Washington, D.C.- based healthcare attorney Elizabeth Hogue.

Many agencies' 11th-hour CoP prep efforts are probably focused on EP, suspects consultant and occupational therapist Karen Vance with BKD in Springfield, Missouri.

But "if agencies haven't already wrestled this issue to the ground, it will be difficult to do so at the last minute," Hogue says.

The problem: "Emergency preparedness requirements, at least to the extent in the CoPs, should not be applied to home health agencies," Hogue contends. "It's one thing for institutional providers to prepare for emergencies when they have control over both the environment in which services are provided and their patients," she says. "Agencies have control over neither, which makes it like pounding a square peg into a round hole to apply extensive emergency preparedness requirements to agencies."

"Because of these factors, agencies have very limited ability to assist patients during emergencies and requirements should reflect this fact," Hogue insists.

Nevertheless, Medicare surveyors will be evaluating agencies on their EP compliance. "In many agencies, the Plan is something purchased and put in a binder and left on the shelf," Haydel says. But on the morning Eli reached her, "we have fires in California and a bombing in New York City and nurses who may be prevented from getting to their patients' homes," she illustrated. Expect surveyors to make sure you are properly prepared.

Care Planning, Coordination Of Services, And Quality of Care

"These are going to be huge pitfalls," believes Sharon Litwin with 5 Star Consultants in Camdenton, Missouri. "They have so many processes to change and so, so, so much education and auditing to do" for these requirements, Litwin tells Eli.

"I read a lot of documentation and it is hard to really see care coordination as part of a culture," says consultant and physical therapist Cindy Krafft with Kornetti & Krafft Healthcare Solutions.

Infection Control

This Condition is going to be a challenge for many, experts predict. "There have been very few studies concerning infection control and home visits. The work environment is the patient's home and there is only so much we can do to control it," Haydel acknowledges on The Coders blog. "We don't have a housekeeping department to mop up our messes with industrial strength cleaning agents like hospital nurses. We cannot fire other family members if they don't wash their hands and what about those pets who jump on the bed after being outside?"

But "without a clean-up crew and a controlled environment, Infection Control is more important than ever," Haydel emphasizes.

Many agencies have IC programs that are "outdated or not implemented, and some of them are frankly too confusing to follow," Haydel warns. And "one approach that has a 100 percent chance of failure is writing or buying a pretty binder and keeping it on the shelf between surveys."

Plus: Home Health Aide training and orientation is another danger area. "The requirements are stricter than before and some agencies will consider it a burden to send a nurse out with the aide," Haydel tells Eli.

Each hot topic may contain its own unique challenges, Haydel illustrates. "Data-driven QA will likely be the most difficult Condition for agency compliance, but I would bet that the Emergency Preparedness Plan and Patient Rights will be most often cited," she offers.