The much-anticipated draft copy of the Interpretive Guidance of the Conditions of Participation (CoPs) for Medicare- and Medicaid-certified home health agencies was made public recently. This draft copy gives additional insight regarding what the Centers for Medicare and Medicaid Services (CMS) expects to find as evidence of compliance to the updated CoPs when surveying and inspecting agencies.
Home health agencies are encouraged to review the interpretive guidance draft and send comments to the National Association for Home Care and Hospice (NAHC) by Friday, November 10. NAHC’s Vice President of Regulatory Affairs, Mary Carr, will be compiling industry comments and submitting them to CMS for review on November 15. Send any comments to Carr at mkc@nahc.org.
Although the final copy of the interpretive guidance is not expected to be released until December, the draft gives important insight regarding expectations for agency compliance. This insight, when combined with the comments from the CoP Final Rule, will assist home health agencies in finalizing their policies and processes before the January 13, 2018, implementation date.
Some of the welcomed insights in the draft copy of the interpretive guidance include:
- Clarification that an associate’s degree is acceptable for administrator requirements;
- Not requiring that mandated updates to the dynamic Plan of Care be sent to the physician for signature each time a verbal order is received; and
- Clarification regarding when patient rights should be presented to the patient rather than his or her legal representative.
As evidenced by the omission of the proposed Home Health Groupings Model (HHGM) from the 2018 HHPPS Final Rule this week, CMS appears to be listening to our industry’s feedback. Sending comments to CMS through NAHC regarding the interpretive guidance is another important opportunity to let your voice be heard.
Axxess continues to support the home health industry by providing free educational resources, including our library of on-demand videos and blogs.
