More than a year after the revised Home Health Conditions of Participation (CoPs) took effect and about four months after the release of related interpretive guidelines, CMS has provided agencies with additional clarifying guidance around the requirements.
On Jan. 23, CMS released 48 frequently asked questions (FAQs) about the interpretive guidelines along with official responses.
The new guidance includes clarifications around the difference between a patient’s legal representative and the patient-selected representative, the definition of the start of care (SOC) and whether “all diagnoses” must be documented on the comprehensive assessment to go to the plan of care.
In addition, CMS also reiterated that agencies can’t use a volunteer or pseudo patient for competency testing of home health aides.