10 Things Your Agency Can Do NOW to prepare for new CoPs


EDITOR’S NOTE: This article first appeared in the March 1 issue of The Absolute Agency, a free best practices resource emailed to agency administrators each month. To subscribe, click here.

It’s been almost 30 years since CMS changed the rules for home health agencies participating in Medicare, but the summer of 2017 will usher in both small and large changes in operational aspects of home health care.
Agencies must be prepared by July to meet most of the newly revised Conditions of Participation, although emergency preparedness plans won’t have to be in place until November.
If you’re feeling intimidated by scope of new changes on the horizon,  Home Health Solutions owner and president J’non Griffin has this advice about how to swallow an elephant:
One bite at a time.
Home Health Solutions will be focusing in greater detail on these and other aspects of the revised CoPs during the next few months, but there’s no need to wait to get your agency ready for the changes. Here’s our To-Do List of 10 simple tweaks, small changes and easy projects you can do right now to prepare for July and get ahead of the game.

1. Create An Organizational Chart.
If your agency doesn’t have one, start one.  Establish a clear chain of command.
Already have an organizational chart? Great! Make sure that it has a Clinical Manager who is responsible for making assignments, coordinating patient care and performing many of the functions currently falling under the duties of a Supervising Nurse.  Having a Clinical Manager is one of the new CoP requirements.
This doesn’t have to be one person. It’s OK to have more than one Clinical Manager on your chart.  Neither will your Clinical Manager have to be an R.N. Under new CoPs, the professional in this role may be nurse, therapist, social worker, even a doctor.
Your organizational chart will need to be in writing, along with all other agency policies.

2.  Create or Review Existing Job Descriptions.
You’ll need a job description in writing for each person who works at your agency – and the job description will need to include licensing requirements as applicable for specific positions. This will vary from state to state, so resist the urge to copy a great job description from an agency in another state.  You’ll have to make sure you do your homework so that your job descriptions are unique to your agency and match your state’s requirements.
Make certain, in the case of your Clinical Manager, that the job description highlights the primary responsibility as COORDINATION of services, patient care, etc.

3.  Check Your Watch. 
Now make it a habit. There’s no time like the present to start cultivating a new habit, and your entire staff is going to need to become much more time-conscious under new CoPs.  Clinicians will need to get into the habit of including the TIME in all visit notes.
There’s new wording in the CoPs, and it’s all about what time it is: time of arrival, time of departure, time that a service was provided,  and what time it was when someone on your staff spoke to a physician. It’s no longer enough to record the date on which an order was received; you’ll need to record the time, too.
Give your staff plenty of time to get into the habit; start requiring the documentation of time today.

4.  Start collecting phone numbers and contact info.
Under new patient rights established by the CoPs, you’ll be required to share with patients the phone numbers, addresses and contact information for a variety of state and federal agencies serving your area, including:
— Agency on Aging
— Center for Independent Living
— Protection and Advocacy Agency
— Aging and Disability Resource Center
— Quality Improvement Organization

5. Update Your Patient Info Packets
While you’re adding the list of numbers and contact info to the patient rights and information packets you provide to your patients at Start of Care, spend some time reviewing and evaluating exactly what you’re handing out and how well it is organized.
Is it easy to understand? Can you edit or rewrite any portion of it to make it simpler or any clearer? Does it spell out clearly how a patient, caregiver or representative is to report a problem or file a complaint – and to whom?
Under new CoPs, you’ll need to make sure to provide the patient with the name, phone number and contact information for both the agency administrator and clinical manager.
Make sure to include in writing your agency’s transfer and discharge policies. New CoPs will require you to provide this information to patients.
There are many other new patient rights requirements, too, but working now on these particular elements now can put your agency ahead of the curve.

 6.  Take steps to erase language barriers.
Make certain your agency can easily provide interpreters and copies of patients rights and information in the native language of the patient. Even if your agency does not currently serve patients who speak a language other than English, you must be prepared to overcome language barriers in the event that such a patient needs your care.
Start developing a plan now for securing interpreters as needed, and draft a written policy addressing how your agency will handle this situation should it occur.

7.  Medication Regimen Review.
Make sure you are conducting a review of all meds the patient is currently using and perform a reconciliation. Clinicians are already asked to do this as part of OASIS, but under new CoPs, your agency will be required to review all medications a patient is taking — including those prescribed by other care providers —  to identify, review and resolve any discrepancies.

8. Speed it up!
Work on getting faster in every aspect of your agency’s operation. Tighten your deadlines and stress to your staff the importance of streamlining and expediting paperwork.  Under new CoPs, you’ll need to have summaries prepared much faster, meet expedited turnaround times, be able to provide complete information to patients by the next home visit upon request, and follow through on discharged patients within a 5 business day window, providing a discharge summary to the agency, physician or other entity into whose care the patient is being transferred.

9.  Take a new look at how to safeguard private health information.
Under new CoPs, you’ll need a detailed written policy establishing procedures to be followed in the event of loss, theft or destruction in any manner of a computer on which private medical records are stored.  This is a good time to start detailing that policy.

10. Start working on your agency’s Emergency Preparedness Plan. 
Agencies have until November to get together the detailed Emergency Preparedness Plan required by new CoPs – but this is a complex undertaking with many components, and getting started today is the best course of action.
Start by calling your local Emergency Preparedness Agency today to set up a time to meet with a representative who can help you with one of the most intimidating pieces of this project for many agencies: the coordination of communitywide resources and other facilities.  FEMA already has access to much of the information you will need for your plan, including detailed studies and existing coordination plans which can be incorporated into the unique plan you will be required to craft for your agency.
As an example, you’ll need both a Hazardous Risk Assessment and a Communication Plan. Flood Risk Assessments from FEMA for your area may provide the specific information you will need to include in your own assessment. Your local agency may also help you develop a workable Communication Plan specifying how to get in touch with staff, patients, patient families and caregivers, as well as other facilities in the community in the event of a disaster which takes down phone and/or power lines, knocks out satellite communications and makes normal channels of communication impossible.

Cross these 10  items off your To-Do List and you’ll already be 10 sizeable bites into the elephant as the calendar turns toward July, ushering in the revised Conditions of Participation.
Bon appetit!

What’s next for home health? Experts at conference admit they’re baffled

In a week of intense debate in the nation’s capital over efforts to repeal and replace Obamacare, the future of myriad home health regulations remains as uncertain as other health care issues. 

But one thing IS certain, according to Home Health Care Solutions owner J’non Griffin, who joined other home health experts at the 2017 Illinois Home Care and Hospice Conference & Exhibition near Chicago this week. Whether lawmakers change, repeal or leave in place existing Medicare requirements, agencies must continue to streamline their processes and focus on quality improvements to remain profitable in the increasingly challenging home health  field. 

Agencies in Florida hoping for a reprieve from an April 1 rollout of pre-claim reviews by the Centers for Medicare and Medicaid Services are likely to be disappointed, according to keynote speaker William Dombi, who serves as The National Home Care Association’s Vice-President  for Law. 

The eyes of the nation remain fixed on the D.C. debate over replacing the Affordable Health Care Act with an as-yet-unnamed plan which has been alternately dubbed Trumpcare,  Ryancare and Obamacare Lite. How the proposed replacement would impact home health has not yet been determined.

Meanwhile, the clock ticks inexorably toward the April 1 deadline in Florida, leaving little time or attention for NACH’s efforts to derail PCRs.

“The Washington perspective is that we are all crazy at this time. No one knows at all,” Dombi told hundreds of home health professionals attending the Illinois conference. “My concern is that day after day, hope of something in Florida diminishes.” 

NAHC has prioritized stopping the PCR process in additional states, including Florida, and curtailing the process in Illinois, which became the first state to undergo a PCR demonstration in August, 2016. Dombi said NACH is petitioning CMS to allow agencies which have had consistently high affirmation rates to opt out of the PCR process without being penalized financially. 

But NAHC’s efforts to get lawmakers to support the repeal of PCRs have been largely overshadowed by the bigger repeal efforts on Capitol Hill, and the political fallout. Republican lawmakers unveiled the replacement health care act promised by the Trump administration this week to major discord in Washington D.C., with condemnation from Democrats, the American Medical Association, the American Hospital Association, and even some Republicans. 

What will happen next is anyone’s guess, Dombi told conference attendees. He describes the situation as “very chaotic.” 

As federal lawmakers grapple with complex issues such as the extent of individual rights to health care, whether responsibility for health care is a federal or state priority and whether the role of the government in health care should be as partner or provider,  Dombi sees some areas of hope on the horizon for home health. 

The new administration’s Secretary of  Health and Human Services, Tom Price, has a sound grasp of many home health concerns and a history of support for many of them, Dombi said. 

Price has indicated some support for delaying new Conditions of Participation for Medicare which are scheduled to become effective July 13, Dombi said.  The new CoPs will require many operational changes for home health agencies, and there is some concern within the industry that there is not enough time for agencies to fully implement all the changes.

With no interpretive guidelines released four months away from the implementation,  NAHC believes surveyors aren’t ready for new CoPs and has been lobbying for a delay. Word in D.C. is that Price is “seriously considering” NAHC’s position, according  to Dombi.

However, it is important to note that no delays of PCRs or CoPs have been approved at this time. Industry experts at the Illinois conference strongly encouraged agencies to proceed as if new Conditions of Participation, Pre-Claim Reviews and Value Based Purchasing initiatives (in which agencies are rewarded or penalized depending on how well they make improvements) are inevitable. 

No one knows if or when or where CMS will expand Value-Based Initiatives beyond the nine states in the current trial, whether PCRs will proceed to other states after the Florida rollout, or exactly what will happen next in home health, but agencies must be prepared anyway, PPS Plus educator Jennifer Warfield told her conference audience.

“Even if the actual term Value Based Purchasing goes away, the future of your agency is always going to be tied to its improvement processes,” she said. 

Joyce Ryan Boin with Strategic Health Care  Solutions encouraged agencies to redirect their focus toward education and ongoing strategy for measurable improvement. 

“We’re not in Kanas any more,” she said. 

 EDITOR’S NOTE:  Check out HHS Owner J’non Griffin’s four-part webinar series on the new Conditions of Participation, providing an overview and highlighting compliance strategies for agencies to develop a QAPI program. The series begins March 15 at 10:30 a.m. CT, and will continue March 29, April 11 and April 25. 
For details or to register, click here.