Conditions of Participation Final Rule Expected at End of Year

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Karen Utterback By Karen Utterback 
Former Vice President, Product Marketing and Strategy, McKesson (Retired)
Conditions of Participation Final Rule Expected

It’s been a long time coming, and it’s still not quite complete. I’m talking about CMS’s Homecare Conditions of Participation (CoP), which was released in 1997 but never finalized. A new version was announced in October, and since some instructions and terminology need to be refined, audience members at this year’s McKesson Homecare & Hospice National Users’ Conference were relieved to learn the final rule won’t be released until the end of this year.

That timing comes from Centers for Medicare & Medicaid Services officials who spoke to Mary St. Pierre, retired vice president of regulatory affairs at the National Association for Home Care and Hospice. St. Pierre, along with Rhonda Oakes, McKesson business systems analyst, conducted a session on the proposed Conditions of Participation. Home health organizations will likely have 90 days to implement the requirements (longer for some aspects), but Oakes and St. Pierre encouraged agencies to act sooner, saying quality of care improvements put in place now will help ease the transition.

The main themes of the Conditions of Participation rule place emphasis on:

  1. Quality of care, including a formal quality-of-care improvement program
  2. Involving patients in all aspects of their care
  3. Consistent improvements in processes, care outcomes and beneficiary satisfaction

Improving quality of care

The rule requires agencies to use CMS’s Quality Assessment Performance Improvement (QAPI) program, already in use in nursing homes and hospices. Oakes pointed out that organizations are already following the majority of these guidelines, just under a different name. She encouraged leaders with hospice partners to lean on them for guidance and not get overly ambitious with the new program.

“Don’t build five new outcomes; you know what you need to be working on,” she said.

Involving patients in their care

Identifying and recording patient goals is a requirement of the proposed Conditions of Participation rule, along with documenting factors that could impact treatment, including knowledge deficits, adherence issues and environment. “Patient goals are usually something related to quality of life,” said Oakes. “For example, ‘I want to be able to walk to my coffee maker.’” As with outcomes, excesses should be avoided. “You don’t want a list of 27. Pick two or three goals that can realistically be accomplished.”

Patients must be given a copy of their care plan initially and each time it changes. St. Pierre has asked that this aspect be amended so that only “significant” changes result in a new plan being given to patients.

The rule requires organizations to keep patients informed in a variety of ways. They must receive their rights both verbally and in writing, and they must sign a copy in advance of care. An interpreter must be provided, if needed, for this exchange. St. Pierre noted that there is currently no emergent-care exception, but she is working to have one included in the final rule.

Patients must be given contact information for the agency’s administrator, as well as information for federal, state and local consumer protection and advocacy agencies. They must also be given clear information about the organization’s policies for admission, transfer and discharge in advance of care.

Improving processes and care outcomes

The Conditions of Participation rule contains a couple of important administrative updates. First, the parent organization must provide supervision and administrative control over branch offices—and is fully responsible for them. Second, individuals who make care decisions but are not the caregiver must be identified in the records as a care representative.

Measurable outcomes are another area of focus, and assessments, like those found in McKesson Homecare™, must now include measureable outcomes regarding the continuing need for home care; medical, nursing, rehab, social and discharge planning needs; and medication review. Oakes noted that McKesson Homecare™ Insight can help organizations meet this requirement. She also encouraged agencies to develop definitions for terms used by everyone in the agency (moderate difficulty, minimal difficulty, etc.).

Said Oakes, “We need to look at our processes and get into alignment across the board. A lot of you already ask what the patient would like to be able to do, so we know their goals. But we often focus on a patient’s ailments rather than pointing out they’re making it longer between hospital visits. We need to point out their strengths, and we need to be intentional about changing the way we do things rather than just doing them the way we always have.”

Continue reading to learn more about the current and pending home health regulations that impact your organization.

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