Solutions

Solutions powered by
Learn More.
abaqis for Skilled Nursing

abaqis®

Mitigate risk and elevate your quality of care. Improving both clinical and business outcomes starts with a smarter, more integrated approach to regulatory training, continuing education and quality management.

Learn More

NEW TO THE STORE

The S.T.A.B.L.E. Program Online Course

Improve quality of care for well and sick infants. Learn how it can transform your ability to accurately monitor and care for infants, improving their quality of life.

AACN ECCO Essentials of Critical Care Orientation

Essentials of Critical Care Orientation (ECCO), from the American Association of Critical-Care Nurses (AACN), is an interactive, case-based course designed to orient nurses on critical care basics.

COVID-19 Support Courses

These courses are designed to educate staff on current guidelines for infection control across various care settings and precautions for airborne pathogens.

LATEST & POPULAR

BLOG

Nurse Strikes are Scary, but License Verification Doesn’t Have to be
BLOG

Ten Trends for 2023: Rising Temperatures and Generational Changes
BLOG

Ten Trends for 2023: CMS Cuts and Other Disruptors
BLOG

Ten Trends for 2023: Hospital at Home and Integration of Behavioral Health and Primary Care
BLOG

Ten Trends for 2023: Emerging Technology and Cybersecurity
BLOG

Ten Trends for 2023: Financial Woes and Staffing

< HealthStream Resources

01761262_ps_494639164

What Are Conditions of Participation (CoPs)?

April 1, 2021
April 1, 2021

What Are CoPs?

CoPs are qualifications developed by CMS that healthcare organizations must meet in order to begin and continue participating in federally funded healthcare programs (Medicare, Medicaid, CHIPS, etc.). These standards involve health and safety guidelines that protect all beneficiaries by improving quality and enforcing patient rights. CoPs apply to all healthcare organizations that participate in federally funded healthcare programs.

Prior to 1986, CoPs were primarily focused on “structure over process measures… such as staff qualifications, written policies and procedures, and committee structure, which were usually specified at the standard level” (McGeary, 1990).

For example, a typical provision was a medical staff meetings standard calling for regular efforts to review, analyze, and evaluate clinical work, using an adequate evaluation method. Explanatory evidence for surveyors included attendance records for meetings involving reviews of clinical practice at least monthly. Conditions were revised in 1986 as part of the Reagan Era’s push for deregulation. Changes involved “eliminating prescriptive requirements specifying credentials or committees, departments, and other organizational arrangements. They were replaced with more general statements of desired performance or outcome in order to increase administrative flexibility” (McGeary, 1990). At the same time, more emphasis was placed on such measures as “infection control and surgical and anesthesia services. In addition, quality assurance was made a separate condition” (McGeary, 1990).

Why CoPs Were Established

CoPs were established to align state licensure requirements and declare minimal health and safety requirements across healthcare organizations throughout the country.

As many as a third of hospitals, especially those in rural areas, did not participate in the voluntary accreditation program of the Joint Commission on Accreditation of Hospitals. Even though a goal of Medicare was to maximize healthcare access, it was evident that existing accreditation programs would not guarantee minimum health and safety conditions in all hospitals (McGeary, 1990). Therefore, the establishment of Medicare included requirements about “the maintenance of clinical records, medical staff bylaws, a 24-hour nursing service supervised by a registered nurse, utilization review planning, institutional planning and capital.

Why CoPs Compliance Is Important

Non-compliance with CoPs can be serious. For example, “If conditions of participation are not met, various sanctions may be imposed upon the provider, including a corrective action plan, monetary sanctions, and increased reporting requirements. While a provider may eventually be excluded from the federal healthcare program, exclusion is relatively rare and only occurs if the provider fails to become substantially compliant during the corrective period” (Lauer et al, 2011).

References

Lauer, K., Ohta, J., and Hargreaves, A., “Violations of Payment/Participation Conditions as Predicates for False Claims,” Health Law Litigation, Spring/Summer 2011, Vol. 9 No. 2, Retrieved at https://www.lw.com/thoughtLeadership/violations-of-payment-participation-conditions-as-predicates-for-false-claims

McGeary, M., Medicare Conditions Of Participation And Accreditation For Hospitals in Medicare: A Strategy for Quality Assurance: VOLUME II Sources and Methods; 1990, Retrieved at https://www.ncbi.nlm.nih.gov/books/NBK235473/

This blog post continues a series excerpting the HealthStream article, Using Assessments and Training to Improve Conditions of Participation, by Debbie Newsholme, Senior Director of Content Development and Compliance Solutions, HealthStream. This article also includes:

  • Why CoPs Compliance Matters
  • Surveys to Determine CoPs Compliance
  • Deficiency Findings and Corrective Plans
  • Connecting the Dots Between the CoPs and Accrediting Standards to Learning
  • How HealthStream Can Help You Meet Cops and Accrediting Standards

To learn more about improving CoPs compliance in healthcare, download the article.