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10 Things to Know about CoPs for Home Health Agencies in 2018

The new Conditions of Participation (CoPs) for Home Health Agencies (HHAs) have been published, and agencies will soon be held accountable to new standards. In a recent webinar, Gina Mazza, a national leader on regulatory and compliance issues and a Partner and the Director of Fazzi’s Regulatory and Compliance Division, shares with HealthStream the details of the additions and revisions made to the existing conditions.

“The new CoPs are transforming our rulebook. It’s 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.

Here are ten takeaways about the new standards:

  1. CoPs for HHAs are standards that agencies must meet in order to participate in the Medicare and Medicaid programs.
  2. The Final Rule can be read in its entirety through the Federal Registrar’s website.
  3. There hasn’t been an update to the CoPs for Home Health in years. A proposed rule was first published in 1997 but was never finalized. There hasn’t been much change since the OASIS requirement was finalized in 2005. In 2014, CMS proposed new rules and a proposal to revise all existing CoPs.
  4. The final rule was published January 13, 2017, was effective July 13, 2017, and the deadline is January 13, 2018. The current document is considered to be an interpretative guideline and CMS is expected to release a finalized version before the deadline.
  5. All Medicare and Medicaid certified HHAs are required to meet the standards of CMS’s new set of CoPs.
  6. There is a continued theme through all CoPs related to care that is integrated, patient-centered, and outcome oriented.
  7. There are new personnel standards that require new administrators to have an undergraduate degree.
  8. Many of the CoPs are a reorganization of existing CoPs. The reorganized CoPs include Patient Rights (484.50), Comprehensive Assessment of Patients (484.55), Care Planning, Coordination of Services, and Quality of Care (484.60), Skilled Professional Services (484.75), and Health Aide Services (484.80). Some of them include new standards within the condition.
  9. There are two brand new conditions. The new conditions are Quality Assurance Performance Improvement (QAPI) (484.65) and Infection Control and Prevention (484.70).
  10. CMS wants to see you partner with the patient—not simply providing care to the patient but with the patient.

Watch the full CoPs Webinar here.

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