Welcome 2018 … and welcome new Medicare Conditions of Participation (COPs). While many set goals for the New Year and hope for success, many agencies are following one basic mantra: get a basic, better understanding of how we can comply with CMS/Medicare regulations. The new COPs are lengthy, complicated, and leave imaginations wandering when trying to actually understand the new meaning of some language.
Interpretive guidelines usually help quite a bit when new regulations are released. However, CMS has only released the drafts which were published in October. Relying on the draft interpretations is a good place to start, but there are some very important areas that the draft interpretations only touch on, leaving your agency to handle on its own.
Strong quality assurance and quality improvement (QA/QI) is one of the areas of the new COPs that agencies must work towards. For agencies that are Joint Commission or CHAP accredited, these new QA/QI requirements may not be so unfamiliar. The Joint Commission played a critical role in shaping and helping CMS revise the COPs.
Agencies are going to need a strong QA/QI plan that focuses on outcomes, tracking information and data, then using that focus and data to make real improvements. We’ve already seen CMS moving towards data driven care with the creation of Home Health Compare star ratings. Now CMS is forcing agencies to perform, show evidence of performance, or face a survey deficiency.
The COPs require agencies to not only do more, but provide tangible evidence that the dusty policy and procedure manual you have is being used. No longer can a policy or procedure be created and forgotten. The new COPs are making sure that agencies are doing what they say they are going to do and in accordance with the guidelines that must be followed as a government contractor.
Emergency preparedness is also a big component of the new COPs. With the recent larger scale natural disasters, having a plan in place for patient care and educating patients on how to leave the home is an essential component of an agency’s intake process. While many software vendors have been slow to provide an electronic version of the individualized emergency plan for patients, agencies must revert to standard paper or NCS/carbon based forms to get this information across to patients. If your agency isn’t providing individualized emergency plans to every patient, this is a huge survey deficiency.
The traditional director of nursing (DON) position has also been eliminated. No longer does a home health agency need a strict DON. Instead, the new COPs allow for a lesser role that leads the clinical aspect of the agency as a clinical manager. A registered nurse is also not required for this position. While the older version of the COPs didn’t require a nurse, it typically fell to a nurse to perform this role. PTs, OTs, and others may now join the ranks as a home health agency clinical manager.
Agency Administrator requirements have been upgraded. Just being the owner of an agency or stating you have experience will no longer do. Administrators must now have a minimum of a bachelor’s degree and be well versed in home health doctrine and the healthcare environment in which an agency operates. For those who are currently administrators and do not have a bachelor’s degree, your position is safe. The COPs will allow all existing administrators to stay as long as they meet the criteria set forth by the prior COPs. New administators are going to face the additional scrutiny.
So are you ready? Do you have the QA/QI data available? Do you know what you should be looking at? Does your clinical manager understand the significance of data in relationship to the new COPs? If you aren’t totally there, you aren’t alone and don’t worry, we can certainly help. Questions, concerns, or just comments – we want to hear them all! Please reach out to us and we can schedule a time to review the COPs that you might have questions about or aren’t sure about. We have significant resources ready to help.