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Happy Friday, CMS delays CoP Enforcement

By Rachel Hammon posted Mar 31,2017 06:01 PM

  

The Center for Medicare and Medicaid (CMS) just published the following rules delaying the effective date of the Conditions of Participation (CoPs) by 6 additional months, to January 13th, 2018.  The announcement also further delays one section of the rule [484.65(d)] related to performance improvement projects to July 13, 2018

Citing the need for agencies to develop processes that will take additional time, this rule allows agencies to gain the education they need and make the changes necessary to conform to the new regulations.  We are continuing our series of education on the CoPs to help agencies do just that.  Remember to register, even if you missed the first parts as all the recordings are free and can be used to provide ongoing education to your staff.  Additionally, we are offering nursing credit for any of the workshops, so your nurses can get their continuing education as well. 

This is a testament to your advocacy.  Many of you were in Washington this month for TAHC&Hs March on Washington, talking about the CoPs and asking your Congressmen to support a delay.  TAHC&H has been working diligently with several national organizations to advocate in unison about the need for a delay.  When we are together we are stronger! 

We encourage all Medicare Certified Home Health providers to continue to work towards implementation of the new rules and to attend our Updated Conditions of Participation for Home Health: What You Should Know to Achieve Success | 7-Part Webinar Series.  

Please visit https://tahch.org/education/upcomingevents to view all upcoming events including the COP webinar series!

Here are the 7 descriptions:

This is a 7-Part Webinar Series which we began in February.  The next live webinar, Part 4, is scheduled for April 12.   All remaining live sessions are held from 12:00 – 1:30 PM CST.  However if you buy the entire series you will automatically receive recordings of all the previous webinars (Parts 1 – 3).

Recording of Part 1 | February 22| Overview of Updated Conditions of Participation: Setting your Priorities of the series will provide agencies with an overview of the revised CoPs, focusing on the changes made to regulation and the rationale behind the changes. These insights will identify which policy and process changes your agency should implement first to ensure compliance and avoid penalties. Substantial organizational changes related to the governing body, Administrator qualifications, and general oversight of management responsibilities related to the provision and oversight of services will be covered. This first workshop will help agencies prioritize their efforts and set out a plan for implementation of updated CoPs.

Recording of Part 2 | March 8 | Patient Rights and Assessments: Will focus on Patient Rights and assessment of patients. The revised patient rights CoP alone covers 6 standards: (1) Notice of rights, (2) Exercise of rights, (3) Rights of the patient, (4) Transfer and discharge, (5) Investigation of complaints, and (6) Accessibility. The new requirements ensure that patients and their caregivers understand their rights using their language of choice, and are provided with written, comprehensive information about the care they will receive. It also creates explicit requirements for patient rights and enhances patient protections. In addition to retaining existing requirements for patient assessments, CMS will require new content for patient assessments, including a psychosocial and cognitive status assessments.

Recording of Part 3 | March 22 | Skilled Professional Services and Home Health Aide Standards: Will set out expectations for professionals who deliver skilled services to home health patients. The CoP covers 3 areas: (1) Skilled professional services, (2) Responsibilities of skilled professionals, and (3) Supervision of skilled professionals. The home health aide CoPs implement the requirements for an individual to be qualified as a home health aide. It covers 9 standards: (1) Home health aide qualifications, (2) Content and duration of home health aide classroom and supervised practical training, (3) Competency evaluation, (4) In-service training, (5) Qualifications for instructors conducting classroom and supervised practical training, (6) Eligible training and competency evaluation organizations, (7) Home health aide assignments and duties, (8) Supervision of home health aides, and (9) Individuals furnishing Medicaid personal care aide-only services under a Medicaid personal care benefit.

Part 4 | April 12 | Care Planning, Coordination of Services, and Quality: Will focus on Care Planning, Coordination of Services, and Quality of Care. The new CoPs require home health agencies to provide patients with their personalized plan of care. This plan of care should explain the services and treatments planned to achieve agreed-upon positive outcomes for those problems noted on comprehensive assessment. The new CoP will also require HHAs to coordinate care between the HHA, the patient's physician, and caregiver to achieve quality outcomes for the patient. Find out what CMS has in mind for these standards.

Part 5 | April 26 | Quality Assessment and Performance Improvement: Will focus on the QAPI program, which replaces 2 existing CoPs: "Group of a professional personnel" and "Evaluation of the agency's program." The new CoP for Quality Assessment and Performance Improvement will cover 5 standards: (1) Program scope, (2) Program data, (3) Program activities, (4) Performance improvement projects, and (5) Executive responsibilities.

Part 6 | May 17 | Infection Prevention and Control:  Will include 3 standards related to infections: (1) Prevention, (2) Control, (3) and Education. Home health agencies will be expected to maintain surveillance and identify and investigate infectious and communicable diseases among patients. Find out how this standard also integrates with your current licensure rules on infection control.

Part 7 | May 24 | Emergency Preparedness: The last part of the series, will include 4 standards related to Emergency Preparedness: (1) Plan development (2) Corresponding policies and procedures (3) Communication plan and (4) Training and testing. This session will also discuss how the CoPs integrate with your agency's current HCSSA licensure expectations and the new Federal Rules related to Emergency Preparedness.

Continuing Education -Each webinar qualifies for 1.5 clock hour Administrator/Alternate and 1.5 contact hour continuing education for nurses. HCSSA Administrators/Alternates: Meets continuing education requirements for Administrators and alternates under HCSSA licensing regulations. See sections 97.259 and 97.260 of the HCSSA licensing regulations for exact Administrator/Alternate education requirements.  

Texas Association for Home Care & Hospice is an approved provider of continuing nursing education by the Texas Nurses Association – Approver, an accredited approver by the American Nurses Credentialing Center's Commission on Accreditation.

Disclosure to Participants: To receive continuing education credits for each webinar, participant must: attend the entire webinar, mail or fax the completed sign in sheet and pay the processing fee for each individual requesting hours: $10.00 for Members. Individuals requesting credit will receive an emailed evaluation and upon completion will be issued a certificate. The display of commercial products does not imply American Nurses Credentialing Center's Commission on Accreditation or Texas Nurses Association approval or endorsement of any commercial products.

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