Conditions of Participation Update

CMS released, via the Federal Register in October, that a review and revision of the home health Conditions of Participation (COPs) should be expected soon.  The last revision that actually took effect was in 1989.  Another attempt was made in 1997, but was shelved due to the pending payment changes from per visit to IPS and finally PPS, the current payment methodology.

There are 4 COPs that are new in addition to the current COPs referenced at §484.55, comprehensive assessment of patients:

Patient Rights:  Each patient would have a focus on their individual rights.

Care Planning, Coordination of Services, & Quality of Care:  More focus should be placed on interdisciplinary approaches to providing patient care from start to end.

Quality Performance (QAPI):  More data driven approaches to patient care that documented levels of care and outcomes would be prevalent in all agencies.  The goal would be for continuous quality improvement.

Infection Control:  Agencies would be mandated to follow standardized methods and protocols to prevent the contraction and transmission of infectious diseases.  The agency’s infection control program would need to be incorporated with QAPI programs established.

For the most part, the COPs are not earth-shattering.  The majority of agencies already perform most of these functions.