CoP Compliance: You Can't Do It Without Your Clinicians!
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.
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. https://www.selectdata.com/clinicians-role-conditions-participation-cops-compliance-select-connect-clinicians/
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.
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