After about 20 years, CMS has moved forward with drastic revisions to its Medicare and Medicaid Home Health Conditions of Participation (CoPs).
 
The 374-page final rule was posted on the Federal Register on Jan. 9. It will be effective July 13 — giving home health agencies only six months to comply.
 
CMS believes the combined changes will cost agencies more than $293 million overall in the first year and about $290 million in years two and thereafter. The revised CoPs will take agencies nearly 3.8 million hours to collect information, according to the final rule.
 
That’s considerably more expensive — and considerably more time consuming — than what CMS listed as the burden in the proposed rule.
 
CMS will establish new CoPs pertaining to:
  • Patient rights. CMS is creating a condition that clearly enumerates patient rights and the steps that must be taken to assure those rights. There’s also a requirement assuring that patients and caregivers have written information about upcoming visits, medication instructions, treatments administered and instructions for care that the patient and caregivers perform.
  • Care planning, coordination of services and quality of care. This will incorporate an interdisciplinary team approach, focusing on care planning, coordination of services and quality of care processes.
  • Quality assessment and performance improvement (QAPI). This incorporates data-driven goals and an evidence-based performance improvement program of an agency’s own design to affect continuing improvement in the quality of care furnished to patients.
  • Infection prevention and control. Agencies will be required to follow accepted standards to prevent and control transmission of infectious diseases. They will be required to educate employees, patients and patients’ caregivers about these standards. Infection control components will need to be part of the QAPI program.
CMS first proposed revisions to the CoPs in 1997. Due to the significant volume of public comments and the rapidly changing nature of the home health industry at that time, this rule in its entirety was never finalized.