What you need to know about the revised Federal CoPs for Home Health care before July 13, 2017.

On January 13, 2017 the new Federal Conditions of Participation for Medicare and Medicaid Certified Home Health Care agencies was published by CMS.  Here’s what CMS was thinking when developing the new rule:

  • Develop a more continuous, integrated care process across all aspects of home health services, based on a patient-centered assessment, care planning, service delivery, and quality assessment and performance improvement.

  • Use a patient-centered, interdisciplinary approach that recognizes the contributions of various skilled professionals and their interactions with each other to meet the patient’s needs. Stress quality improvements by incorporating an outcome-oriented, data-driven, quality assessment and performance improvement program specific to each HHA.

  • Eliminate the focus on administrative process requirements that lack adequate consensus or evidence that they are predictive of either achieving clinically relevant outcomes for patients or preventing harmful outcomes for patients.

  • Safeguard patient rights.

https://www.federalregister.gov/d/2017-00283/p-25

So, what does that mean to your day-to-day operations?

Until the State issues the interpretive guidelines (which are not expected until the implementation date of 13 July 2017) it’s up to agencies to figure it out on their own.  I’ve highlighted the changes that will affect your Home Health Aides here:

  • Beginning July 13, 2017 therapists can write the home health aide care plan.
  • CMS has clarified the intent of the rule when a State’s Aide training requirements conflicts with the Federal Rule: The more stringent training standard will prevail (currently, in the State of Indiana, the Federal Rule is the more stringent standard).
  • Aides will be expected to participate in interdisciplinary team meetings.
  • A noted deficiency in an Aide’s performance during supervision will now require a complete competency reassessment  , by a RN, of the aide instead of simply retraining the aide relevant to the noted deficiency.
  • New requirements for the specifics of aide supervision content and documentation.  Now supervisory visits must include specific documentation of the aide’s ongoing competence in documentation, communication, following the plan of care and competency in the assigned tasks, infection control, reporting changes in condition, and honoring patient rights.

FMI, use this link to the rule commentary for home health aides in its entirety: https://www.federalregister.gov/d/2017-00283/p-460