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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