Home Health & Hospice Week

Medicare tweaked testing IGs — but not enough.

The final Interpretive Guidelines for the Home Health Conditions of Participation contain a little good news and a lot of bad news for home health agencies when it comes to competency testing for home health aides.

The downside of the final IGs is that competency testing for aides “still requires that validation of competency be completed on a patient rather than on another person in a laboratory setting,” points out consultant Kathy Roby with Qualidigm based in Wethersfield, Connecticut. The CoPs effective this past January address the issue at 484.80(c)(1).

When the Centers for Medicare & Medicaid Services removed the language allowing competency testing on a “pseudo-patient” in the draft IGs, and stated that “the following skills must be evaluated by observing the aide’s performance while carrying out the task with a patient … (ix) Appropriate and safe techniques in performing personal hygiene and grooming tasks that include … (B) Sponge, tub, and shower bath,” home health agencies hoped CMS would modify the language in the final IGs to allow testing on pseudo-patients such as peers and volunteers, or to change the “and” to an “or” in the “Sponge, tub, and shower bath” statement (see Eli’s HCW, Vol. XXVII, No. 16).

CMS did neither in the CoPs. Requiring competency testing on actual patients “represents a critical investment of time, staffing and scheduling to bring the new aides to patients’ homes for this validation,” Roby tells Eli.

Bright spot: CMS did, however, clarify that aide competency applies only to new employees after Jan. 13, 2018, says consultant J’non Griffin, owner of Home Health Solutions in Carbon Hill, Alabama.

The final IGs add this statement: “HHA aides who successfully completed a competency evaluation prior to January 13, 2018, do not need to repeat the portions of the competency evaluation required to be done while providing services to a patient under §484.80 (b) (i), (iii), (ix), (x), and (xi). For all HHA aides who receive a competency evaluation after January 13, 2018, however, these skills must be tested while the aide is providing care to a patient.”

Note: See the new final IGs released Aug. 31 at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/QSO18-25-HHA.pdf.