CMS Finalizes Revisions to CoPs, Allowing Agencies More Time to Prepare for QAPI

Posted on Friday, January 13, 2017 4:13 PM

Agencies have about six more months left to comply for the changes made to the Home Health Conditions of Participation (CoPs). However, CMS granted an extended timeframe until January 2018 for agencies to begin conducting performance improvement projects related to Quality Assessment and Performance Improvement (QAPI).

The drastic revisions to CMS’ Medicare and Medicaid CoPs are detailed in the 374-page final rule.

The major revisions to the CoPs include:
• Patient rights
• Care planning
• Coordination of services and quality of care
• Infection prevention and control
• QAPI (HHL 10/13/14)

The transition to the revised CoPs won’t be as major for the many agencies that already have performed quality improvement projects, care coordination efforts and taken steps to improve patient-centered care, says Joy Cameron, Vice President for Policy and Innovation for the Visiting Nurse Associations of America.

But not all agencies will be as prepared, and it’s going to be “an extreme lift” for agencies that have taken no steps in any of the areas mentioned within the CoPs, Cameron adds.

Overall, it’s also “incredibly unfair” to give agencies a mere six months to prepare, despite the proposed rule being released in 2014, contends attorney Robert Markette of Indianapolis-based Hall, Render, Killian, Heath & Lyman.

Although it’s good that a portion of QAPI won’t be required for a year, agencies can’t sit on their laurels to get started, Cameron adds.

CMS agreed to give agencies one year to begin conducting performance improvement projects related to QAPI. That’s because “it will take additional time to collect the data necessary to identify areas for improvement that are appropriate for performance improvement.”

Agencies are required to provide written instructions to patients and caregivers that outlines their visit schedules, including the following:
• Frequency of visits
• Medication schedule/instructions
• Treatments administered by agency employees and employees acting on the agency’s behalf
• Pertinent instructions related to patient care and the name and contact information of the agency’s clinical manager

“We believe that these requirements will ensure that patients are actively engaged in their own care,” CMS writes. Among the forms of communication agencies can use to facilitate patient understanding about care provided: Typed summaries, checklists, calendars, handwritten notes, secure electronic communications or orientation videos. “Providing patients and caregivers written instructions that they may refer to between visits is critical to both the quality and safety of patient care,” CMS writes.

CMS has decided to allow oral communication of patient rights in the patient’s primary or preferred language to occur prior to the completion of the second skilled visit.

The change, CMS writes, “will foster greater patient understanding of those rights, as well as assure that the conversation does not inappropriately impede with the delivery of patient care.”

Other changes from the proposed rule
• Agencies won’t need to routinely provide patients with their plans of care
• Proposals related to discharge summaries were withdrawn
• CMS removed a requirement for administrators to receive questions from patients
• CMS withdrew a proposal to require aides to be taught to recognize and report changes in pressure ulcers
• Minimum personnel background requirements for clinical managers were finalized at §484.115(c)
• The ASAP system will be taken into account
• CMS listed names of federally funded and state-funded consumer information, protection and advocacy agencies that providers, at a minimum, must give patients

Corridor’s QAPI for Home Health: A Step-by-Step Approach will prepare your agency with a foundation of how to choose Performance Improvement Projects (PIP), how to gather data, how to analyze the data and how to make “real life” enhancements to improve patient care processes and organizational efficiency.

For the full article, please see the January 16, 2017 Home Health Line Edition.

About Corridor

Corridor is the nation’s preferred partner and trusted business advisor to home health and hospice providers, providing quality services and impactful results for 30 years. Focusing on key operational, regulatory and financial challenges, Corridor delivering industry-unique solutions and deep expertise in coding, clinical documentation review, compliance, billing and collections , consulting and provider staff education . At Corridor, we make the business of caring for people Better! For the most important industry updates and news that impacts home health and hospice, please make sure to sign up for our weekly newsletter to receive the latest up-to-date industry information direct to your inbox!

For additional information, please contact Corridor at 1-866-263-3795.

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