CoP Educational Series Part 2: Subpart A – General Provisions

Posted on Friday, July 7, 2017 4:56 PM

It is important to understand Subpart A – General Provisions and any changes included with the finalization of the new CoPs to better prepare your organization for the transition.

Subpart A – General Provisions has been reorganized to better clarify the basis and scope of this section of the CoPs. Part 484.1 is based on sections 1861(o) and 1891 of the Act, which establish the conditions that a home health agency must meet in order to participate in the Medicare program. Part 484.1 is also based on section 1861(z) of the Act, which specifies the institutional planning standards that home health agencies must meet. These provisions serve as the basis for survey activities for the purposes of determining whether an agency meets the requirements for participation in Medicare.

With the revision of the Home Health CoPs several new definitions were added, some were revised and others were eliminated. First, the definitions that were modified will be outlined.

The definition for “branch office”, which means an approved location or site from which a home health agency provides services within a geographic area the parent home health agency provides services was modified by adding the requirement of the parent agency to offer more than just the sharing of services. The definition now includes the parent agency to provide supervision and administrative control of branches on a daily basis to the extent the branch depends on the parent agency’s supervision and administrative control to meet the CoPs, and would not be able to do so independently. The definition no longer requires the branch office to be “sufficiently close”. The parent agency must be available to meet the needs of any situation and respond to issues that could arise with respect to patient care and/or the administration of the agency. A violation of a CoP in one branch office is a violation for the entire home health agency. 

Minor changes are also noted in the language of the current definitions for “clinical note,” “parent home health agency,” “proprietary agency,” and “subdivision.”  

Current definitions of the terms bylaws, supervision, progress notes and sub-units were eliminated.  As it relates to sub-units, on the effective date of the new CoPs, any existing subunits, which already operate under their own provider number, will be considered distinct HHAs and will be required to independently meet all CoPs, including having an independent governing body and administrator. Subject to state-specific laws and regulations, this federal regulatory change will permit a subunit to apply to become a branch of its existing parent HHA, if the parent provides “. . . direct support and administrative control” of the branch. The State Survey Agency and CMS Regional Office will continue to be responsible for approving home health agency applications for a branch office, in accordance with current CMS guidance as set forth in various survey and certification letters and the section of the State Operations Manual. No new subunits will be approved upon implementation of this regulation, only “branch offices.”

Several new definitions were added to the CoPs. 

“In advance” means the home health agency staff must complete the specified task before any hands on patient-care or patient education takes place.

“Quality Indicator” references a specific, valid and reliable measure of access, care outcomes or satisfaction, or a measure of a process of care.

“Representative” means the patient’s legal representative, such as a guardian, who makes health care decisions on the patient’s behalf, or a patient-selected representative who participates in making decisions related to the patient’s well-being, including but not limited to a family member or an advocate for the patient.

“Supervised practical training” means training in a practicum laboratory or other setting in which the trainee demonstrates knowledge while providing the covered services to an individual under the direct supervision of a registered nurse or a licensed practical nurse who is under the supervision of a registered nurse.

“Verbal Order” is a physician’s order that is spoken to appropriate personnel and put into writing to document and as well as establish or revise the patient’s plan of care.

Be sure to read Part 3 of the CoPs blog series which covers Subpart B – Patient Care.

Written by Peggy Patton, Vice President of Education Services

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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!

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