Home Health & Hospice Week

Just keep waiting on those CoP Interpretive Guidelines.

Home health agency survey citations are racking up, and yet the Interpretive Guidelines for surveyors regarding the new Home Health Conditions of Participation that took effect in January are still not out.

Reminder: Back on March 9, the Centers for Medicare & Medicaid Services' Peggye Wilkerson at the ElevatingHOME National Leadership Conference held in Washington, D.C., said that CMS expected the IGs to come out in another six to eight weeks (see Eli's HCW, Vol. XXVII, No. 11).

That informal eight-week time frame has come and gone, and in the May 15 Home Health Open Door Forum, a caller asked CMS for a revised estimate of when CMS will issue the IGs. CMS declined to answer the question, saying it didn't have relevant staff on the call to field the inquiry.

Some industry veterans fear CMS may never issue a final version of the IGs. CMS may opt to just issue clarifications through Quality Safety & Oversight (formerly known as Survey & Certification) letters, worries attorney Robert Markette Jr. with Hall Render in Indianapolis.

Meanwhile, HHAs can get an idea of which CoPs will give them the most trouble by looking at the citations surveyors have handed down so far in 2018. On its Quality Certification & Oversight Reports website, which launched last fall, CMS lists 983 surveys conducted in CY 2018, as of press time.

At the head of the pack is a G tag for Plan of Care problems at 17 percent, with the next citation reason for medication review somewhat far behind at nearly 11 percent (see top 10 citation list, p. 146).

To see a complete accounting of the home health survey citations handed out so far this year, go to https://qcor.cms.gov; choose "Citation Frequency" from the "Deficiency Reports" section in the left-hand column, and choose the criteria for your report. More survey reports are also available to run.