CMS has issued new guidance that explains how agencies can go about converting subunits to branches or independent home health agencies.
The guidance was released fewer than two months before the implementation date of the revised Home Health Conditions of Participation (CoPs).
In a Survey and Cert letter dated Nov. 17, the federal Medicare agency explains the three options affected agencies are presented with: Elect to become a distinct/freestanding agency, elect to become a branch of a parent or elect to terminate participation in Medicare.
The revised CoPs, which take effect Jan. 13, no longer allow for subunits.

Although the subunit issue affects only about 216 agencies nationwide, it was among the reasons why CMS had explained it needed to delay the CoPs six months — until January 2018 (HHL 11/20/17). Some providers had argued they wouldn’t be able to effectively make the conversion until CMS issued further sub-regulatory guidance about subunits.