Understanding the Conditions of Participation (COPs) for Home Health Agencies in 2018

April 1, 2021
April 1, 2021

This blog post is an excerpt from our article, Understanding the Conditions of Participation for Home Health Agencies in 2018.

Over the last twenty years, there has been little change to the Conditions of Participation (CoPs) that home health agencies (HHAs) must follow to participate in Medicare and Medicaid programs. “The CoPs have been the same throughout my entire career,” says Gina Mazza, a national leader on regulatory and compliance issues and a Partner and the Director of Fazzi’s Regulatory and Compliance Division.

The new rule was effective July 13, 2017, and all Medicare and Medicaid certified HHAs were required to meet the standards of CMS’s new set of CoPs by January 13, 2018. Mazza shares with HealthStream her insight on the new CoPs for HHAs in light of the approaching deadline.

Overview of CoPs Changes

“The new CoPs are transforming our rulebook. They are asking us as an industry to start working toward patient-centered, integrated care management and to use our data to make decisions,” Mazza explains. The changes and additions are extensive, specifically detailed, and will require close attention and hard work to implement.

In summary of the new rule, Mazza explains that some of the CoPs are a reorganization of existing CoPs, there are two brand new conditions, there are new personnel requirements for administrators, and there is a theme throughout all CoPs related to care that is integrated, patient-centered, and outcome-oriented. Rather than describing each CoP and standard, Mazza details the areas that are new, problematic, and those that she is commonly questioned about. Highlighted in the following sections are Mazza’s comments regarding the changed or new parts of each standard, not the standard in its entirety.

Focus on Patient-Centered, Integrated Care

“Remember, one of the main and strongest themes related to these new CoPs is that CMS is asking us to be partners with the patient,” Mazza concludes. “Not simply to provide care to the patient but with the patient.”

Mazza reminds organizations to be looking for the finalized interpretative guidelines to be released, and in the meantime to make every effort to close the loops, allowing the provision of patient-centered, integrated care management.

The full article examines:

  • Existing Conditions of Participation (CoPs)—Reorganized and with New Content
  • New Conditions of Participation (CoPs)

Download the article here.