On January 13, 2017 CMS published the final rule for the Conditions of Participation (CoPs) for Home Health Agencies. This is the first update to the CoPs since 1997. The implementation date for HHAs to comply with the new requirements is Jan. 13, 2018.

The CoPs are minimum standards that agencies must meet as a requirement to participate in the Medicare program. Failure to comply with the CoPs can result in sanctions and potentially result in an agency termination from the Medicare program. CMS designed the updated CoPs with the goal of improving the quality of care for Medicare and Medicaid beneficiaries and boosting patients’ rights.

The CoP update is based on a proposed rule CMS released in October 2014. Many of the new requirements are significant changes and CMS estimates the cost of implementation will be $293.3 million in the first year and $290.1 million in subsequent years.

What’s New in CoPs

CMS is still developing the Interpretive Guidelines and State Operations Manual which will be based on the new home health CoPs. On October 27, 2017, CMS released a draft of the interpretive guidelines for review and comment to select industry groups. The guidelines are intended to describe to the home health industry what it means to CMS to be in compliance with the CoPs. Once finalized, they will serve to further interpret and clarify the revised CoPs.  A state surveyor will use the interpretive guidelines to verify compliance with the CMS requirements.

CMS aims for the CoPs to integrate home health care processes based on patient-centered activities and performance improvement.  Care coordination will be key as agencies will be required to take an interdisciplinary approach to meet patient needs and improve communication with patients. Quality improvements are defined and will be outcomes-based and data driven. With the updated CoPs, CMS also sought to eliminate some of the administrative process requirements that do not contribute to quality patient outcomes.

CMS has added two new conditions for home health agencies to comply with;

1) Quality Assessment and Performance Improvement (QAPI)

2) Infection Control

In addition, CMS eliminated four of the current conditions;

1) Subunits

2) The Professional Advisory Committee

3) Quarterly Record Reviews

4) 60-day Summary Requirements

The Conditions have been regrouped into three sections [read more about the sections];

1) General Provisions

2) Patient Care

3) Organizational Environment

About The Contributor

Matthew McGowan, Consulting Manager

Matt has more than a decade of experience in health care financial consulting. He leads revenue recovery engagements for home health agencies that have enhanced the Medicare billing operations and enabled them to achieve continued increases to their bottom line.