By John H. Fisher II
February 14, 2017
The Center for Medicare and Medicaid Services has issued a final rule that revises and modernizes the Conditions of Participation (COP) for Home Health Agencies. The Final Rule can be found in its entirety at: Final Home Health Rule (CMS-3819-F).
The new Rule describes the conditions Home Health Agencies (HHA) must meet in order to participate in the Medicare and Medicaid programs. The new Rule reflects some significant changes in the rules that apply to Medicare HHAs and require HHAs to take a solid look at their policies, procedures, and operations to be certain they comply with the new requirements by the effective date of July 13, 2017.
The changes reflected in the new Rule are intended by CMS to be an integral part of an overall effort to achieve broad-based, measurable improvements in the quality of care furnished through the Medicare and Medicaid programs, while at the same time eliminating unnecessary procedural burdens on providers.
The new Rule generally focuses on the care delivered to patients, reflects an interdisciplinary view of patient care, allows HHAs greater flexibility in meeting quality care standards, and eliminates unnecessary procedural requirements. The primary coverage areas of the new Rule include:
- A focus on assuring the protection and promotion of patient rights.
- Enhancement of the process for care planning, delivery, and coordination of services.
- Building a foundation for ongoing, data-driven, agency-wide quality improvement.
- Expansion of patient rights requirements that enumerate rights of home health agency patients and steps that must be taken to assure those rights.
- Expansion of comprehensive patient assessment requirements focusing on all aspects of patient wellbeing.
- A focus on measures intended to assure patients and caregivers have written information about upcoming visits, medication instructions, treatments administered, instructions for care the patient and caregivers perform, and the name and contact information of a home health agency clinical manager.
- New requirements to promote an integrated communication system to help ensure patient needs are identified and addressed, care is coordinated among all disciplines, and there is active communication between the home health agency and the patient’s physician(s).
- New standards for a data-driven, agency-wide quality assessment and performance improvement (QAPI) program that continually evaluates and improves agency care for all patients at all times.
- Enhanced infection prevention and control requirements with a focus on the use of standard infection control practices, and patient/caregiver education and teaching.
- Streamlining of some of the requirements relating to skilled professional services which emphasize appropriate patient care activities and supervision across all disciplines.
- An expanded patient care coordination requirement for a licensed clinician to be responsible for all patient care services, such as coordinating referrals and assuring that plans of care meet each patient’s needs at all times.
- Revisions to simplify the organizational structure of home health agencies while continuing to allow parent agencies and their branches.
- Revised personnel qualifications for home health agency administrators and clinical managers.
Other Home Health Agency Changes Announced by CMS
In addition to the revised conditions of participation, here are a few additional items impacting home health agencies that have recently been announced by CMS:
TEP Summary Report for Refinement of the Pressure Ulcer Measure. A summary report for the refinement of percent of residents or patients with pressure ulcers that are new or worsened (Short-Stay) (NQF #0678) has been made available through the HHA IMPACT Act Downloads and Videos webpage. This report summarizes proceedings from a follow-up cross-setting pressure ulcer TEP meeting, which included in-depth discussion on the following topics:
- Obtaining input on updates to the cross-setting pressure ulcer measure in post-acute care settings;
- Obtaining feedback regarding potential updates to measure specifications and items used to calculate the quality measure; and
- Refining the cross-setting approach to data collection for pressure ulcers in post-acute care settings.
Changes Under Consideration to Quality of Patient Care Star Ratings. During a National Provider Call on January 19, 2017, CMS described a change under consideration to the Quality of Patient Care calculation algorithm. CMS is considering replacing the Influenza Immunization Received for Current Flu Season measure with the claims-based Emergency Department Use without Hospitalization measure. The slides from the call, which provide additional information, are available on the call detail page. Public comment on the change will be accepted through February 20, 2017.
Update to Home Health Compare. The first 2017 update for HH Compare is scheduled for late January 2017. This update will include the Quality of Patient Care star rating and quality measure values shown in the preview reports distributed in early October, via CASPER. Six measures have been dropped from the public-facing HH compare site during the January 2017 refresh, as finalized in the 2017 HH PPS rule. However, these measures will still appear on the preview reports for another few refresh cycles, because of production processes. The six process measures that have been removed from the HH QRP include (i) Pain Assessment Conducted; (ii) Pain Interventions Implemented during All Episodes of Care; (iii) Pressure Ulcer Risk Assessment Conducted; (iv) Pressure Ulcer Prevention in Plan of Care; (v) Pressure Ulcer Prevention Implemented during All Episodes of Care; and (vi) Heart Failure Symptoms Addressed during All Episodes of Care.
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