Conditions of Participation (CoPs): Patient Engagement - Start Preparing Now!

The majority of newly revised CoP standards become effective in less than four months, July 13, 2017. Have you conducted your gap analysis yet?


The new CoPs signal a shift from problem-focused care that CMS acknowledges has had “inherent limits” to quality focused individualized care. CMS wants to “transform” care delivery.

The new CoPs (See Select Data ezine February, 2017) promote actively involving the patient in their care. CMS stresses focusing on patient strengths as well as their specific outcome goals. The CoPs also stress using individualized communication methods with patients such as schedules, handwritten notes and charts, etc.

How will your agency consistently involve patients, build on their strengths, and work toward mutual outcomes? Some Home Health agencies, in seeking to reduce care fragmentation and improving continuity of care are turning toward integrative models of care.

Patient care has changed with greater demands for multi professional teamwork to offering patients collaboration and coordination. More traditional models tend to focus on isolated interventions rather than the total care needs of the patient. Traditional models frequently offer only partial solutions for improving outcomes and coordination of the care process.

Integrated Care Models can be central to the patient-centered organizational design and performance. Without integration, health care performance can suffer. This “bottom up” approach to care views patient characteristics and strengths as essential for care plan development. This partnering with patients, families, caregivers, and professional members of the team promotes health literacy and ongoing engaged patient self-management.

The cornerstone to integrated care depends on Motivational Interviewing (MI). Motivational Interviewing is a “method that works on facilitating and engaging intrinsic motivation within the client in order to change behavior” (Miller and Rollnick, 2002). MI is goal oriented and patient centered and it is non- confrontational. MI involves developing the ability to ask open-ended questions, to provide affirmations, increase use of reflective listening, and to provide summaries of care provided as well as progress toward goals.

Those skills are used strategically reflecting on a typical day and desired change importance. MI is non- argumentative, understanding that knowledge alone disseminated to patients usually will not change behavior. MI requires working with patients to assess their motivators to change behavior which may not be consistent with their personal goals.

Motivational Interviewing uses four general processes:

Engaging– This means actively involving the patient in talking about their concerns. Engaging requires the clinician to visit with patients and seek their perspective on their health, solicit their interests, and ask about the patient’s desired goals. This is very different than going into the home to “assess” the patient and tell them the plan or to merely “educate” them regarding their disease and its process.

Focusing– This process involves narrowing conversation to patterns the patient wants to change. This is a skill that requires practice by the clinician but is highly effective in helping the patient, in a positive manner, to view expressed desired goals and congruence or incongruence with action toward the goals.

Evoking– This is a learned technique used to determine the patient’s sense of change readiness.

Planning– This process assists in the development of truly collaborative steps to attain goals.

One of the key factors learned in using MI in the home health visit process is that structure is essential for visits. Each visit should begin by 1. listening to the patient/caregiver discuss progress or issues encountered since the last visit. Discussion should discuss prior visit assignments; i.e. increasing ambulation steps by 20 each day. 2. Discussing today’s visit activities and goals so they are clear and any questions or comments can be shared. 3. At the conclusion of the visit, the clinician should review what was accomplished during that visit, review any assignments for either the patient or clinician, seek any comments, and discuss the next visit date and time.

MI broadens patient/caregiver and clinician perspectives and builds on the momentum for behavior change which can ultimately mean improved outcomes. To learn more about Integrated Care Management consider training and certification at Sutter Center for Integrated Care. Here is a link for more information:

There are training programs at numerous hospitals including Mass General. For further information contact them at:

There are numerous books regarding Integrated Care and/or Motivational Interviewing including: Motivational Interviewing by William Miller and Stephen Rollnick.

For more information regarding CoPs or assistance in document review, clinical/coding audits, and Revenue Cycle Management, contact Select Data at 1.800.332.0555.

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