Use Your Time Wisely During CoPs Delay

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Rhonda Perrin Oaks, RN, CHP By Rhonda Perrin Oakes, RN, CHPN 
Regulatory Analyst, Change Healthcare
Use Your Time Wisely During CoPs Delay

The six-month delay in implementing the CMS home health Conditions of Participation (CoPs) until January 13, 2018, comes at an opportune time. The final rule from the Centers for Medicare & Medicaid Services (CMS) represents a fundamental shift in care, with more collaboration and more data-driven outcomes.

Already, home health organizations are expressing concerns about relationships with referring physicians who order home health services for a specific condition (such as hip replacement).  The ordering physicians are not accustomed to having to review and sign off on all the new plan of care CoP requirements. The expectations of Home Health Agencies under the updated CoPs is to deliver more integrated coordinated care, and communicate that information to ordering physicians and other providers.

The importance of care coordination has been underscored by a new report from the RAND Corp., prepared for the Partnership to Fight Chronic Disease. The report builds on previous studies about the prevalence of chronic conditions among Medicare recipients and their related costs.  This report adds insight as to why the CoPs were changed to reflect the care processes that best serve the patients we care for.

Using the Medical Expenditure Panel Survey (MEPS) from the Agency for Healthcare Research and Quality, the study found that:

  • 60% of American adults had at least one chronic condition
  • 42% percent had more than one chronic condition
  • 12% have five or more chronic conditions that account for 41% of total healthcare spending
  • Hypertension and high cholesterol were the most common chronic conditions
  • Those with at least three chronic conditions account for two-thirds of total healthcare spending

The authors suggest the prevalence and cost of chronic conditions is, if anything, underreported. The report explains MEPS relies on self-reporting, which would exclude the 3% of adults who were in long-term care facilities when the data was collected and those who do not know they have a chronic condition. Additionally, MEPS spending has been shown to be low by as much as 17.6%.

More robust software

Individuals with multiple conditions often have multiple doctors. Organizations should use a software solution that can demonstrate a continuous, integrated care process across all aspects of care that’s based on a patient-centered assessment and continuous care planning.  The home health organization is the manager of the care and coordination of that care while the patient is on service and during transitions of care.

The updated CoPs are intended “to focus on a patient-centered, data-driven, outcome-oriented process that promotes high quality patient care at all times for all patients,” according to the background information published with the rule by CMS.

CMS cited the following principles to guide it in developing the new home health CoPs:

  • Develop a more continuous, integrated care process across all aspects of home health services, based on a patient-centered assessment, care planning, service delivery, and quality assessment and performance improvement.
  • Use a patient-centered, interdisciplinary approach that recognizes the contributions of various skilled professionals and their interactions with each other to meet the patient’s needs. Stress quality improvements by incorporating an outcome-oriented, data-driven, quality assessment and performance improvement program specific to each HHA.

Patient conditions aren’t simply a hip replacement, congestive heart failure, early onset dementia or any other single ICD-10 code. When home health enters the picture, a single condition may be the specific need for home health, but patient co-morbidities and chronic conditions often require contribution from multiple health providers.  This paradigm shift pressures home health agencies to take on a more holistic role in care processes, reflective of care management models that are becoming more common in value based care.

Care coordination under the Medicare Conditions of Participation will promote referring providers and others to keep in the loop on the care plan and the patient’s progress towards their desired goals. These changes should be supported with not only robust software that facilitates secure data exchange –  but also a delicate touch to educate physicians about the new requirements, their roles and their responsibilities.

Take the six-month delay as an opportunity to do both.

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