Viewing posts categorised under: Conditions of Participation (CoPs)

CoP Interpretive Guidelines: Are You Compliant?

Clinical Documentation Improvement, Clinical Practices, Compliance, Conditions of Participation (CoPs), HIPPA

CoP Interpretive Guidelines: Are You Compliant?

Are You Compliant With CoP §484.60?

Home Health Agency Condition of participation (CoP) went into effect January 13, 2018 (CMS, 2018). However, some agencies are still struggling when it comes to Condition of participation (CoP). According to the CoP Interpretive Guidelines, to be compliant with CoP §484.60, home health agencies must have established standards of practice issued by a nationally recognized organization with expertise in the field. If your organization fails to meet these minimum standards when audited, you may be assessed a monetary fine or lose your Medicare certification.

§ 484.60 Condition of participation: Care planning, coordination of services, and quality of care.

Patients are accepted for treatment on the reasonable expectation that an HHA can meet the patient's medical, nursing, rehabilitative, and social needs in his or her place of residence. Each patient must receive an individualized written plan of care, including any revisions or additions. The individualized plan of care must specify the care and services necessary to meet the patient-specific needs as identified in the comprehensive assessment, including identification of the responsible discipline(s), and the measurable outcomes that the HHA anticipates will occur as a result of implementing and coordinating the plan of care. The individualized plan of care must also specify the patient and caregiver education and training. Services must be furnished in accordance with accepted standards of practice.

(a)Standard: Plan of care.

Each patient must receive the home health services that are written in an individualized plan of care that identifies patient-specific measurable outcomes and goals, and which is established, periodically reviewed, and signed by a doctor of medicine, osteopathy, or podiatry acting within the scope of his or her state license, certification, or registration. If a physician refers a patient under a plan of care that cannot be completed until after an evaluation visit, the physician is consulted to approve additions or modifications to the original plan.

(2) The individualized plan of care must include the following:

(i) All pertinent diagnoses;

(ii) The patient's mental, psychosocial, and cognitive status;

(iii) The types of services, supplies, and equipment required;

(iv) The frequency and duration of visits to be made;

(v) Prognosis;

(vi) Rehabilitation potential;

(vii) Functional limitations;

(viii) Activities permitted;

(ix) Nutritional requirements;

(x) All medications and treatments;

(xi) Safety measures to protect against injury;

(xii) A description of the patient's risk for emergency department visits and hospital re-admission, and all necessary interventions to address the underlying risk factors.

(xiii) Patient and caregiver education and training to facilitate timely discharge;

(xiv) Patient-specific interventions and education; measurable outcomes and goals identified by the HHA and the patient;

(xv) Information related to any advanced directives; and

(xvi) Any additional items the HHA or physician may choose to include.

(3) All patient care orders, including verbal orders, must be recorded in the plan of care.

(b)Standard: Conformance with physician orders.

(1) Drugs, services, and treatments are administered only as ordered by a physician.

(2) Influenza and pneumococcal vaccines may be administered per agency policy developed in consultation with a physician, and after an assessment of the patient to determine for contraindications.

(3) Verbal orders must be accepted only by personnel authorized to do so by applicable state laws and regulations and by the HHA's internal policies.

(4) When services are provided on the basis of a physician's verbal orders, a nurse acting in accordance with state licensure requirements, or other qualified practitioner responsible for furnishing or supervising the ordered services, in accordance with state law and the HHA's policies, must document the orders in the patient's clinical record, and sign, date, and time the orders. Verbal orders must be authenticated and dated by the physician in accordance with applicable state laws and regulations, as well as the HHA's internal policies.

(c)Standard: Review and revision of the plan of care.

(1) The individualized plan of care must be reviewed and revised by the physician who is responsible for the home health plan of care and the HHA as frequently as the patient's condition or needs require, but no less frequently than once every 60 days, beginning with the start of care date. The HHA must promptly alert the relevant physician(s) to any changes in the patient's condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered.

(2) A revised plan of care must reflect current information from the patient's updated comprehensive assessment, and contain information concerning the patient's progress toward the measurable outcomes and goals identified by the HHA and patient in the plan of care.

(3) Revisions to the plan of care must be communicated as follows:

(i) Any revision to the plan of care due to a change in patient health status must be communicated to the patientrepresentative (if any), caregiver, and all physicians issuing orders for the HHA plan of care.

(ii) Any revisions related to plans for the patient's discharge must be communicated to the patientrepresentative, caregiver, all physicians issuing orders for the HHA plan of care, and the patient's primary care practitioner or other health care professional who will be responsible for providing care and services to the patient after discharge from the HHA (if any).

(d)Standard: Coordination of care. The HHA must:

(1) Assure communication with all physicians involved in the plan of care.

(2) Integrate orders from all physicians involved in the plan of care to assure the coordination of all services and interventions provided to the patient.

(3) Integrate services, whether services are provided directly or under arrangement, to assure the identification of patient needs and factors that could affect patient safety and treatment effectiveness and the coordination of care provided by all disciplines.

(4) Coordinate care delivery to meet the patient's needs, and involve the patientrepresentative (if any), and caregiver(s), as appropriate, in the coordination of care activities.

(5) Ensure that each patient, and his or her caregiver(s) where applicable, receive ongoing education and training provided by the u, as appropriate, regarding the care and services identified in the plan of care. The HHA must provide training, as necessary, to ensure a timely discharge.

(e)Standard: Written information to the patient. The HHA must provide the patient and caregiver with a copy of written instructions outlining:

(1) Visit schedule, including frequency of visits by HHA personnel and personnel acting on behalf of the HHA.

(2) Patient medication schedule/instructions, including: medication name, dosage and frequency and which medications will be administered by HHA personnel and personnel acting on behalf of the HHA.

(3) Any treatments to be administered by HHA personnel and personnel acting on behalf of the HHA, including therapy services.

(4) Any other pertinent instruction related to the patient's care and treatments that the HHA will provide, specific to the patient's care needs.

(5) Name and contact information of the HHA clinical manager (Cornell Law School, 2018).

Need Help with your agency's Condition of participation (CoP) compliance?

For more information about how Select Data can ensure CoP Interpretive Guidelines have been met email or call 800-332-0555.

Resources Centers for Medicare & Medicaid Services (2018). Center for Clinical Standards and Quality /Quality, Safety & Oversight Group. Department of Human and Health Services. Retrieved from: Cornell Law School (2018). 42 CFR 484.60 - Condition of participation: Care planning, coordination of services, and quality of care. Legal Information Institute. Retrieved from:
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians Click here to read more.
Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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CoPs Breakdown on the New QAPI Regulations

Clinical Documentation Improvement, Clinical Practices, Coding, Compliance, Conditions of Participation (CoPs)

CoPs Breakdown on the New QAPI Regulations

Adopt New Techniques

On January 13th, the rules for CoP's Quality Assessment and Performance Improvement regulations changed. Section 484.65 QAPI has replaced sections 484.16 (Group of Professional Personnel) and 484.52 (Evaluation of the agency’s program). The new section does a great deal to highlight the responsibilities of the agency's executive team and expects the governing bodies to focus on technology concepts like data- driven indicators to identify, track, and measure quality initiatives for high risk, high volume or safety issues. The program includes 5 standards: • Program Scope 484.65 (a) • Program Data 484.65 (b) • Program Activities 484.65 (c) • Performance Improvement Projects 484.65 (d) • Executive Responsibilities 484.65 (e) Program Scope Agencies are required to develop a data-driven QAPI program with measurable improvement indicators. The organization must measure, analyze, and track quality indicators including a patient’s adverse events, as well as other signs of performance to assess processes, services, and operations. However, it is not enough to just create the indicators. Agencies must use data to provide evidence that the improvement has led to improved health outcomes (ex: reduced hospitalizations, ED visits), safety and quality of care for patients. Program Data The QAPI program must utilize quality indicator data, including measures derived from OASIS that CMS has reported, to assess the quality of care provided to the patients and identify, prioritize, and manage opportunities for improvement. The QA efforts, including data collection, should focus on high-priority safety and health conditions. Like the program scope, data collected should support the quality measures and identify opportunities for improvement. Agencies will need to focus on those areas of past performance which have proven problematic for the agency over time or areas where there was clear evidence of poor patient outcomes as well as high risk and high volume. Program Activities The QAPI activities should include incidence, prevalence, and severity of problems in those areas. So that preventative actions and mechanisms can be implemented, agencies must track and analyze activities over time to ensure sustained improvements. Management should immediately correct any issues identified that directly or potentially threaten the health and safety of patients. Performance Improvement Projects The QAPI program requires that agencies performance improvement projects be conducted annually, at a minimum. The plan should reflect each agencies unique scope, complexity, and past performance. There should be clear documentation of the QAPI projects including the reason for conducting these projects and the measurable progress achieved. The agency’s governing body must define, implement, and maintain a program for quality improvement and patient safety that is ongoing and agency-wide. Executive Responsibilities The governing body for each agency is responsible for ensuring the QAPI reflects the complexity of the organization and its services, including contract and arrangement, are focused on indicators related to improved outcomes. They must also approve the frequency and level of detail in data collection. The governing body should establish clear expectations for patient safety and address issues in performance across the spectrum of care including the prevention and reduction of medical errors. For more information on this topic or on our Document review and Coding Services or Revenue Cycle Management, please call Select Data at 1.800.332.0555.
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Making the Most of Your Home Visits

Clinical Documentation Improvement, Clinical Practices, Coding, Conditions of Participation (CoPs)

Making the Most of Your Home Visits

Advocate For Your Patients and Yourself

The Clinician's Role Home health patients are often referred from a facility. Therefore, transitioning from a well-equipped, well-staffed environment to receiving care at home can be a daunting task for the patient and his or her care givers. Home Health clinicians play a huge role in making this transition go smoother. It is imperative that clinicians are strong in their communication, education, assessment, and leadership skills. With experience, clinicians will develop a skillset that assists in completing a visit systematically. With ever increasing regulatory demands and a growing senior population, it’s easy, especially for less experienced clinicians, to become overwhelmed during the flurry of activity that can happen during a home visit. From time to time even veteran clinicians should reevaluate their routines to make sure they are delivering excellent care while being efficient and methodical. This article has some tips to help clinicians evaluate and improve their routines. Accurate Documentation Visits need to be completed in a timely manner and in accordance with CMS regulations. Be sure to follow MD specific orders for admissions and/or discharges. OASIS item M0102 and M0104 (MD ordered SOC & Date of Referral) are process measure items and impacts star ratings, therefore accuracy is very important. Make sure your great care is well represented with great documentation. Be organized and have structure for the patient’s assessment and care. Set an appointment with the patient for visits. Consider the patient’s preference regarding the visit time. Their input may assist in a more productive experience. Once an appointment is set, plan accordingly. Map out the driving route to the home and consider any potential weather impact or road construction to prevent unnecessary delays. Prepare for the visit by reviewing all paperwork, including the referral and physician documentation. Knowing about the patient’s recent procedures, medical and social history, and current living arrangement will be beneficial. These topics are often discussed in the physician’s History & Physical documentation. Keep supplies organized, readily available for care during the visit to prevent wasted time. Once in the patient’s home, stay on task and have a plan. Remember why you are there and execute the job at hand, while also making the patient feel important and involved. Focus on the patient and their needs. Do not allow the visit focus to turn to anyone else. Build trust and a good rapport with the patient as the opportunities present themselves. Assist the patient in understanding what to expect. Be attentive to their concerns, but do not allow the visit to be consumed by Q & A. Remove distractions as needed. Personal distractions should be avoided, such as cell phones or a preoccupied mindset. Distractions within the home may also need to be addressed (for example: pets, a loud TV or music, too many people around). Go into every visit with end goals in place and conduct the course of the visit in a way to get closer to meeting those goals. If the visit begins to veer of off the course you have planned, politely redirect its path. Accurate Documentation Is Good For Patients and Clinicians  Paint a true picture of your patient and their living conditions. This can often lead to an MSW or therapy referral to meet types of needs that may never be identified in a facility setting. Remember, if it isn’t documented, it didn’t happen. Therefore always be thorough in this part of your care. Make eye contact as much as possible, but attempt to jot down important information that you are gathering as you go. Start observing as soon as you pull into the driveway. Look at the yard, front porch and the condition of overall surroundings for safety hazards and concerns. Note who answers the door. If it is the patient, assess their speech, gait, demeanor, etc. from the very beginning to assist you in your overall assessment. Observe the cleanliness of the home and how it may impact the patient and their care. Be aware of the other people in the home. Keep the patient’s safety and your own safety as top priorities. Make sure you speak clearly and in a manner that the patient can understand. Use common terms and explain procedures, plans, and paperwork. Exhibit warmth and empathy through your communication. Overcome barriers – speech, hearing, and vision then note whether specific therapy referrals are appropriate. Listen to the patient and address their needs, requests, and concerns. Their involvement in the visit, development of Plan of Care, and overall outcome will be determined by the visits. Communication extends to within the home health agency as well. Always provide a report time to other clinicians that will follow you into a home. It is also a good practice to attempt to inform the patient of who will be included in the care. The new Conditions of Participation place a strong emphasis on care coordination. Watch For Signs Patient safety is an essential factor that the visiting clinician must assess. Monitor family members to gauge any suspicious behavior that is indicative of abuse or neglect. Be aware of what the signs are of elder abuse. Be mindful of animals, especially dogs. Anticipate problems and position yourself close to the door with ease of exit at any point during the visit. Maintain your car and gas. Be available to leave on a second’s notice. Keep your cell phone charged and always have a plan. If a situation arises, stay calm. Do not be manipulated by anger, fear, or sadness. Plan the visit in a way that eases the patient into the uncomfortable subjects at the right times. Be empathetic by stating the obvious, that things are personal and somewhat uncomfortable to talk about. Make sure to document any behavior that is aggressive. Report concerning behavior to the Clinical Manager and physician, as these situations need to be addressed quickly to prevent escalation. Patients of advancing age fear the loss of independence. Assure your patient that they are still involved in their care and remind them of their rights. Being a provider can take a toll on someone physically, emotionally, and mentally. Take time off when needed and minimize the time you take work home. Don’t be afraid to ask for help or for a break. Advocate for your patients and yourself. References:
To watch Tips & Trips on Making the Most of Your Home Visits live presentation fill out your name and email address

Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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CoP Compliance – You Can’t Do It Without Your Clinicians!

Clinical Documentation Improvement, Clinical Practices, Coding, Compliance, Conditions of Participation (CoPs), HIPPA, Uncategorized

CoP Compliance: You Can't Do It Without Your Clinicians!

CMS expects Conditions of Participation (CoPs) 100% Compliance on January 13th.

"January Funk" Shortly after ringing in the new year, people have been known to get the blues. Winters are cold, days are short, there’s not another holiday for months, and many people fall into what some call “The January Funk.” If you work in an industry that involves a lot of regulatory involvement, like healthcare, you may fall into a “January headache.” In healthcare, guidance, policy, and regulations are often updated, and new programs are launched at the beginning of the calendar year. For home health providers, saying “goodbye” to 2017 means saying “hello” to updated Conditions of Participation (CoPs) from CMS in 2018. After researching hundreds of pages of documentation, your head may be spinning as you lament over where to start. After all, just working in the home health business can keep your mind busy 24/7, never mind having more heaved onto your plate. With the new CoPs implementation quickly approaching, we’re in the warm up phase right now. If it hasn’t happened yet, it’s time for you to gather your team and start your pep talk. The success of any home health agency depends on teamwork. That’s now a new concept. Now is the time that your clinicians need to start wrapping their heads around how their life is going to be changing because of the updated regulations. Do you already have a plan in place for communicating to patients with limited English language skills? Do your clinicians know what the Patient’s Rights are? Since clinicians are just weeks away from having to give a verbal explanation of the Patient’s Rights to the patients, it’s time to start rehearsing. Clinician competency will be a key to your success, or the lack thereof will be the torpedo that sinks your battleship. Call your team together and let’s get the planning started. First, your team needs to know that these changes are coming, and that they are nothing to be afraid of. It seems that in healthcare when new policies (or regulatory changes) come around there is the feeling of impending doom. “What do we have to do now?” I recommend that you do an overview with your clinicians and let them know what exactly are the conditions of participation and why they are being updated. It’s time to discuss the paradigm shifts regarding CMS’s approach to patient care. It also may take a certain degree of convincing to get your long time veteran clinicians to buy into the idea of patient centered healthcare that is driven by the patient’s strengths and preferences. If your staff doesn’t buy into this new philosophy, there’s little chance that your patients are going to be convinced to shift their thinking. Eliminate Potential Anxiety For Your Clinicians After you get past the “why”, it’s time to get your paper out and start sketching out the “how.” Your clinicians need to clearly understand what part of their routine must change. What signatures do they need to get and when? What’s the phone number for the interpreter’s line? Are you going to publish your agency’s literature in different languages? How do you explain a patient’s right to people with different educational backgrounds and different cognitive ability? Your clinicians are much more likely to be compliant with the updated Conditions of Participation if you help eliminate some of the potential anxiety that accompanies change. Start talking about these things now. It’s not fair to throw clinicians into a new situation without the proper preparation. We’ve all been there, and we all know that it stinks to be there. Start coaching them now so they’re set up for success. Develop tools to get the job done right. Are there different fields that need to be custom added to your EMR so that the additional required information will have a home? If that’s not possible, you should work with your team to develop check lists (or worksheets) so that they are reminded of everything they need to ask or say during that home visit. Look at the tools you have now and decide what changes need to be made. When clinicians are forced to “do things on the fly” without the proper tools, they often find themselves jotting down random information in a disorganized and in a “non-HIPAA compliant” manner. Eventually, when this all of this becomes more familiar, your clinicians will probably develop their own system. While they’re just becoming accustomed to these new requirements, make sure they have the tools to be organized and efficient. Five-Day Window Coordination is a huge factor in the new Conditions of Participation. For coordination to be successful, good communication is a must. Unfortunately, communication is where many teams take shortcuts. The Clinical Manager role that is defined in the CoPs is immense. An agency’s Clinical Manager is only going to be successful if your team has a great communication plan. Communication about a patient’s care plan will be ongoing but it will be especially hectic at the time of admission. The communication plan among clinicians of different disciplines, multiple doctors’ offices, and the administrative staff, must be well thought out, organized and adhered to. Figure out how you’re going to manage all the information in the beginning five-day window, or your Clinical Manager may end up climbing out of the office window to escape. Practice, Practice, Practice! Finally, it’s time for your team to start practicing. There’s nothing that prevents you from implementing some of these changes before the beginning of the year. CMS expects you to be compliant with the updated Conditions of Participation 100% of the time on January 13th. Don’t wait until early one January morning to try and throw these ideas together. You’re not making a quick regulatory snack. You’re creating a huge feast of regulatory changes. Some of us know from experience that you shouldn’t be making your grocery list the day before Thanksgiving as your in-laws are in route to your home. Don’t wait until the beginning of January to bring in donuts for your clinical team so that you can “brainstorm this new thing.” Your clinicians are a key to your Conditions of Participation compliance. Invest in them. Train them. Listen to them. Invite them to join in on important conversations. Their success will lead to good patient outcomes. Isn’t that why we’re doing this after all? For more information about the implementation of the new Conditions of Participation please view our webinar from October. For more information on this topic or on our USA based Document review and Coding Services or Revenue Cycle Management, please call Select Data at 1.800.332.0555.
Related Article - CoPs Breakdown On The QAPI Regulations
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New CoPs: New Assessment Tools and Forms

Clinical Documentation Improvement, Conditions of Participation (CoPs)

New Conditions of Participation (CoPs): New Assessment Tools and Forms

Are You Ready?

CMS is obviously seeking more precise and exact assessments of patient and care giver needs. As to the care givers, CMS expects the clinician to be observant for signs of stress and the burden of caring for the patient. That means using a tool that can assist to ascertain the level of stress and “quickly screen for the level of care giver strain.” ‘Have you been searching for such a tool? One such tool to consider is the Modified Caregiver Strain Index (MCSI). It is a thirteen-question tool that can measure strain related to care provision with domains in finance, physical, physiological, social, and personal. There are no age constrains or requirements. It is quick and easy to learn to administer. It is also less of a burden for caregivers. Like many tools, there are strengths and weaknesses with the tool. You will need to evaluate. There is also a Caregiver Burden Scale which accompanies the tool and can provide more detail as to caregiver needs. Scoring on this scale looks at patient needs, caregiver tasks, and caregiver burden (Macera, C, A., Eaker, E.D. Etal 1993. A measure of perceived burden among caregivers, evaluation and the health profession 16(2), pages 204-211). Care for the patient means looking at patient needs as well as care giver needs. This tool provides guidance in this area.

Cognitive Test Results May be a New Requirement in 2019. Will you be Ready?

Begin getting familiar with the Confusion Assessment Method (CAM), a tool that seeks patterns of behavior and cognitive functioning of patients.  CMS is committed to having the testing for cognitive status as data supports the fact that patients with lower cognitive functioning have higher incidence of falls, rehospitalization rates, and higher non compliance with plans of care. CMS is looking at the MDS 3.0 version for use because of its ability to look at the behavioral symptoms. These are not a focus of the present OASIS C2. As you can see, CMS is seeking a more indepth assessment of patients so that more precise plans of care may be implemented. Starting now to educate clinicians in better understanding delirium and reversible confusion as well as becoming familiar with the CAM can be very helpful now and for future preparation. For all of your document review and coding needs. Contact the specialists at Select Data.
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians Click here to read more.

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The Clinician’s Role in Conditions of Participation (CoPs) Compliance | Select Connect with Clinicians

Clinical Documentation Improvement, Clinical Practices, Coding, Compliance, Conditions of Participation (CoPs)

The Clinician's Role in Conditions of Participation (CoPs) Compliance

Live Recording from October's Select Connects With Clinicians

In this session, attendees will be able discuss the importance of Conditions of Participation (CoPs) and compliance with Home Health patient care.

Conditions of Participation (CoPs) Compliance Overview:

    • A New Model for Home Health Patient Care
    • How did we get there?
    • Reducing Risk
To watch The Clinician's Role in Conditions of Participation Compliance live presentation fill out your name and email address

Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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OASIS C2 and Active Diagnoses: Are Your Agency’s Answers Setting You Up for Potential Issues?

Clinical Practices, Coding, Conditions of Participation (CoPs), ICD-10 CM, OASIS-C2

OASIS C2 and Active Diagnoses

Are Your Agency’s Answers Setting You Up for Potential Issues?

OASIS C2 has proven to have caused difficulty for many agencies. One key reason is M1028. Agencies must remember that a physician must validate if a patient has diabetes and/or PVD/PAD. In addition, the physician must determine if the diagnosis is active. The clinician cannot make that determination.   The OASIS Manual explains that these diagnoses influence the patient’s functional outcomes or risk for developing pressure ulcers. These are keen areas of concern to CMS. As a result, CMS is paying close attention to active diagnoses. Conditions that are resolved are not listed. Most patients with diabetes or PVD/PAD will have those as an active diagnosis but a clinician must not jump to conclusions. A physician must confirm the diagnosis is active and the agency should note that confirmation date.   The Clinical/Coding specialists should review the patient’s clinical record carefully for documentation to support the diagnosis and the plans for care. Review the medication profile, the comprehensive assessment, and the visit notes for related information as well as for congruency between the documentation. Pay close attention to M1028 but also to all active diagnoses.   Per CMS, active diagnoses are diagnoses that have a direct relationship to the patient’s current functional, cognitive, mood or behavior status; medical treatments; nurse monitoring; or risk of death at the time of the assessment. Note that CMS is honing in on the functional, cognitive, and behavioral status of the patients. It appears they are looking closely at active diagnoses, certain specific diagnoses, as well as the assessment of the patient…a very comprehensive assessment. They expect the assessment to support the diagnoses.   In the new Conditions of Participation (CoPs), CMS states that the “comprehensive assessment must identify the psychosocial, functional, and cognitive status of the patient including evaluating and screening any patient psychological and social condition that may complicate HHA service delivery or inhibit the patient’s ability to understand, remember, and participate in developing and implementing the plan of care.”   In summary, carefully answer M1028 but note all diagnoses must be confirmed by a physician. Be certain those confirmations are documented. Expand your comprehensive assessment to have a detailed psychosocial, functional, and cognitive assessment.   Remember, assessment and diagnoses are a focus of CMS. Make them your focus also.  For expert documentation review and coding, contact the Select Data Specialists.
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CoPs Delayed a Proposed 6 Months. Breathe a Sigh of Relief, but Don’t Relax as You Have Much Work to do.

Clinical Practices, Conditions of Participation (CoPs), Healthcare, HIPPA, Legislation, Uncategorized

CoPs Delayed a Proposed 6 Months!!!

Breathe a Sigh of Relief, but Don’t Relax as You Have Much Work to do.

CMS has proposed delaying the new Conditions of Participation (CoPs) for six months, until January 13, 2018.  QAPI  implementation would be required in July, 2018. Though a 60 day comment period is required, it is unlikely that home health agencies will complain and demand to implement the new CoPs sooner, so industry experts are saying we can presume the delay will occur. Agencies have expressed relief as the CoP changes were significant and many HHA expressed concern that there was inadequate time to prepare.  But don’t sit back with this postponement. You have much work to do. The Changes in General The organizational structure of the regulations was changed dividing the general provisions into three subparts: general provisions, patient care, and organizational environment. Certain CoPs were consolidated; i.e. Skilled Nursing, Therapy Services, and Medical Social Services were consolidated into Professional Services. Two CoPs were added; Quality Assessment and PI (QAPI) and Infection prevention and control. Many of the remaining standards were revised significantly: Patient Rights, Comprehensive Assessment, Care Planning/Care Coordination, Home Health Aide, Organization and Administration, Clinical Records, and Personnel Qualifications. The CMS Focus The focus is one of integrated care processes including:
  1. A patient-centered assessment with measureable outcomes.
  2. Patient-specific care planning and service delivery
  3. Agency-specific processes for Quality Assessment and Performance with active Governing Body involvement
  Transforming the CoPs CMS has found that directing a QA approach toward identifying providers that furnish poor quality or failed to meet minimum Federal standards does not always  work. CMS stated, “We have found that this problem-focused approach has inherent limits.” CMS wants to stimulate broad-based improvements in the quality of care delivered to all patients.  They want “Patient-centered, data-driven, outcome-oriented processes promoting high quality care for all patients at all times.” Surveyors are undergoing intensive new training. Some of the Action Items that an Agency May Need to Complete Intensive education for all personnel especially in the areas of patient rights, comprehensive assessment with ongoing POC updates, and patient engagement. Active patient involvement in their POC. New updated Patient Rights Forms with names and addresses and phone numbers of care givers.  Have space on the form for the Patient/Legal Representative to sign. Make certain the new CoP language is included in the Patient Rights form. Have copies of policies regarding admission, transfer, and discharge available for patients that reflect the new standards. Be certain the patient knows the Clinical Manager’s name and number to call with any clinical questions. It is now required under the CoPs to provide the Administrator’s name and number to call with any complaints. CMS is seeking a more “holistic patient assessment.” This means they expect the agency to develop a better understanding of the patient; knowing their strengths and abilities for active involvement in their own care plan and ultimate outcomes. How will your agency ensure this process?  Will it be Integrative Care Management?  Is education and training needed? Educate personnel to identify signs and symptoms of stress in the caregiver as well as how to speak with the caregiver re strain and burdens of care. Will you use a screening tool? Identify where you will note the education and training for patients and their specific needs. A one- size fits all care plan for a specific diagnosis will no longer be sufficient. How will revisions to the care plan be flagged so clinicians know they are working with the most current POC? The POC is to become an “evolving document.” CMS is stressing team care. The new CoPs require agencies to coordinate care delivery. How will your HH interdisciplinary team communicate? “Coordinated care requires communication with integration of orders with all physicians.” A patient hospital risk assessment is required for all HHA admissions.” All patient orders, including verbal orders must be recorded in the POC. They must have not only the date, but the time of the order noted. “The HHA must develop, implement, evaluate, and maintain an effective ongoing, HHA-wide, data-driven program. The HHA governing body must ensure that the program reflects the complexity of its organization and services, involves all HHA services including those services provided under contract or arrangement, focuses on indicators needed to improve outcomes, including hospital admissions and readmissions and takes actions that address the HHA performance across the spectrum of care including the prevention and reduction of medical errors. The HHA must maintain documentary evidence of the QAPI program and be able to demonstrate its operation to CMS.” A plan to educate/ consult with the Governing body re the new CoPs as well as each QAPI project is required. Agency must create new policies and procedures, modify and/or update certain old P&P in keeping with new CoPs and consolidation of certain old standards. Are new job description modifications needed? As to infection control; what new P&P are needed? What surveillance, identification, prevention, control, and investigation program will be put in place to meet the new standard?  Of course this will require further education and training for personnel. As to home health aides: What education and training modifications will be required to meet the new communication requirements? What changes will be needed to the policies, procedures, and job descriptions? What about your agency cybersecurity and Emergency Preparedness Plans? Your system must include a system of medical documentation that preserves patient information, protects confidentiality, and maintains availability of records. So, you may think of the postponement as a reprieve, but it is a short one. As you can see…there is much to do, so get started now. For assistance with your coding, documentation review, and revenue cycle management needs, contact Select Data at 1.800.332.0555. We are  100% USA based, here to assist you.
Related articles New Conditions of Participation (CoPs) and Your Agency Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians webinar on December 14, 2016. Click here to read more. Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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