Good news, bad news
There’s good news in the home health field this week:
Yes, there is a possibility that the federal Center for Medicare and Medicaid Services will delay the implementation of revised Conditions of Participation, allowing home health agencies extra time to make the many clinical, organizational and administrative changes which will be required.
The bad news is that a possible delay doesn’t mean agencies can afford to wait to begin working on meeting the new requirements.
In fact, Home Health Solutions Owner and President J’non Griffin advises home health agencies to move forward with all changes as if there will be no change in the effective date established under current law.
The need to begin work now on the many changes required under CoPs is especially true for creating Emergency Preparedness Plans, which will likely be one of the more labor-intensive and intimidating new requirements for agencies, J’non said.
Conditions of Participation will require home health agencies to have in place a detailed Emergency Preparedness Plan including hazard risk assessments for their specific communities, communication plans for any natural or man-made disaster and many other specific components.
Under the Final Rule approved in January, agencies have until November 2017 to put together this complex Emergency Preparation Plan, and have in place measures for conducting community-coordinated disaster drills to practice how they would handle their patients and work with other facilities during an actual emergency situation. In addition, the agency’s emergency preparedness program will need to include individual plans for its patients.
Last week’s announcement by CMS that it will consider a delayed start date for CoPs, pushing the current effective date from July 13 2017 to January 13 2018 made no mention of a new time frame for the Emergency Preparedness Plan requirement.
Until otherwise notified, agencies must assume that the November 2017 deadline stands, according to Home Health Solutions LLC Owner and President J’non Griffin.
There is no guarantee that CMS will approve any delays, despite last week’s announcement, and agencies could be risking non-compliance if they do not move forward with changes, J’non said.
“CMS has opened a 60-day public comment period to solicit information it will use in making the determination about whether to delay the start date for CoPs,” J’non said. “But it is important to remember that if the start date is not delayed at the end of the 60-day period, agencies which have not begun to make the necessary changes will not have enough time to do so by July 13.”
Need help with your Emergency Plan?
A complete Emergency Preparedness Plan Assembly Kit is one of the resources and products Home Health Solutions has created to help agencies meet the new CoPs.