Big changes are afoot in the home health industry.

Understanding the new Medicare conditions of participation


Big changes are afoot in the home health industry. For the first time since the 1980s, the Centers for Medicare & Medicaid Services has finalized new conditions of participation (CoPs) for home health agencies to participate in the Medicare program. If you haven’t yet, read the rule in its entirety.

The changes go into effect on Jan. 13, 2018, and CMS just released a draft of its interpretive guidelines on Oct. 27. That means HHAs need to do everything they can in November and December to familiarize themselves with the new rules – and the draft guidance – and prepare for January compliance.

Background on revisions 
In 1997, CMS proposed a rule that included landmark revisions to CoPs for HHAs. However, due to public pushback and major developments in the home health industry, CMS ultimately dropped the CoPs changes and kept the second half of the rule, which was the Outcome and Assessment Information Set (OASIS).

Yet CMS held onto the idea that it could still update the CoPs as it had intended to six years prior. However, in 2004 the U.S. Federal Register interpreted a related act as actually “rendering ineffective any proposed Medicare regulations that had been outstanding for three years or more.” As a result, CMS scrapped the 1997 proposal and set to work developing an entirely new CoPs rule, resulting in a proposal released in 2014 that was finalized this year.

Understanding the changes 
The ultimate goal of the new CoPs is to improve patient care.

“[The rule] … reflects current best practices for in-home care, based on recommendations from stakeholders and medical evidence,” said CMS Chief Medical Officer Kate Goodrich.

“The new rule emphasizes enhanced customization of patient care.”

The new CoPs focus on three main areas:

  1. Patient-centered care.
  2. Data-drive collaboration.
  3. Outcome-oriented processes.

Patient-centered care: The new rule emphasizes enhanced customization of patient care through the creation of an individualized Plan of Care (PoC) based on a more patient-centered assessment. The patient-oriented goal is further reinforced with the conditions requiring HHAs to share clear and comprehensive documentation with patients concerning their rights, as well as written information about the details of their care.

Data-driven collaboration: The CoP rule demands greater care coordination efforts and expanded interdisciplinary communication to ensure all providers involved in patient care are focused on the patient’s needs. This targeted approach places an even higher priority on interoperability of patient data between HHAs and other providers. Detailed PoCs need to be readable, shareable and accessible by all stakeholders.

Outcome-oriented processes: The new rule also emphasizes progress toward patient care goals. This is seen in its radically new Quality Assurance Performance Improvement CoP, which tracks HHAs’ progress toward achieving specific outcomes. As part of QAPI, HHAs will have to undertake Performance Improvement Projects at least annually that measure progress in identified problem areas.

Preparing for change 
If you feel that the new Medicare CoPs are overwhelming, you’re not alone. But by learning as much as you can about the rule and its guidance now, and taking steps to prepare your agency to implement the changes, you can experience a smoother transition come January.