The Centers for Medicare and Medicaid Services’ new Conditions of Participation (COP) for home health agencies went into effect in January.1 The COP lays out the rules your home health agency must follow if it wants to be reimbursed for treating Medicare and Medicaid patients.2

McKesson asked Maria Lugo, vice president of post-acute care field sales at McKesson Medical Surgical, about the new COP and how CMS’ new rules will affect the nearly 13,000 home health agencies (HHAs) currently participating in the Medicare program. We also asked Lugo to identify the things your agency can do to comply with the new rules without jeopardizing your financial performance.

Why did CMS update its COP for home health providers?

Lugo: The last time Medicare updated the Conditions of Participation for home health was well over 30 years ago. An update was needed because so much has changed in home health over that period. The number of people receiving care in the home has increased dramatically. The sophistication of the care that can be provided in the home has increased dramatically. And patients and their caregivers are much more involved in their own home care services.

Complying with CMS's New Conditions of Participation for Home Health Agencies
What’s the biggest change in the COP for home health providers?

Lugo: The biggest change is the new care plan requirements. In the past, a home health nurse would assess the patient and discuss the care plan with the physician. The physician would sign off on the care plan and that was that. Now the process starts with a comprehensive patient assessment. The HHA is required to update the assessment each time there’s a major change—good or bad—in the patient’s condition. The HHA also must update the assessment on a regular basis and following a major event like a hospital readmission. As a result, the care plan based on the assessment becomes a living, breathing document that’s continually updated with new patient health information, new outcome goals and new treatment protocols to be followed by doctors, nurses and aides.

What other major changes in the COP should home health providers be aware of?

Lugo: The two others are the quality assessment and performance improvement (QAPI) program and the integrated communication system requirements. The QAPI requirement means an HHA must have a system in place that collects, measures, analyzes and reports outcome data. The HHA must use the data to improve performance across its operations. The integrated communication system provision means an HHA must have a process in place to communicate any change in a patient’s care plan to the patient, the patient’s family, the patient’s primary care doctor, any other doctor involved in the patient’s care, and any other member of the coordinated care team.

How will the major changes in the COP that you’ve identified affect home health providers?

Lugo: It puts a lot on their plate at a time when they’re trying to reduce operating costs in response to tightening reimbursement. The new care plan requirement means more people have to update the care plan more frequently. As the care plan is updated, more people will have to be notified more frequently. Also, anyone who comes in contact with a patient becomes part of the interdisciplinary care team, including now the home health aide. And as a member of the interdisciplinary care team, each person must assess the patient and document what’s happening with the patient on an ongoing basis.

From an operational perspective, how will the changes affect most home health providers?

Lugo: The biggest practical impact will be on documentation. An HHA no longer will be able to function on a paper-based system. The new COP makes that absolutely impossible.  An HHA must have an EHR system that’s capable of capturing assessment information from multiple sources on an ongoing basis. The system needs to update and share care plans with all members of the interdisciplinary care team. It also must be able to collect, analyze and report performance data. Without a good EHR system, an HHA likely will struggle to perform these tasks.

Will there be any practical effects on staffing or staff skillsets?

Lugo: Yes. The new COP makes every person who cares for the patient part of the interdisciplinary care team. That means each person must be adept at assessments and clinical documentation. The new COP specifies that home health aides are part of the care team. As such, aides need to possess certain basic skills, including the ability to observe, report and document the patient’s health status and the care or services they provided to the patient. The new COP also specifies that an HHA make a licensed clinician responsible for all patient care services provided to a patient, including coordinating that patient’s care with other members of the disciplinary team and referring that patient to other providers.

How much will complying with the new COP cost home health providers?

Lugo: In the final regulations implementing the new COP, CMS estimated the cost to comply with all the new COP requirements will be a collective $293.3 million for all HHAs during the first year the new rules are in effect. CMS said HHAs will spend most of the money—about $182.4 million—on new information collection requirements. They’ll spend $37.5 million on new infection control requirements and another $29.1 million to comply with the QAPI system requirement.

What steps can home health providers take to cost-effectively meet the new COP requirements?

Lugo: The number one thing home health providers can do to meet CMS’ new COP is to take advantage of technology. That means having a robust EHR system with all the capabilities I mentioned earlier. HHAs also should take advantage of remote health monitoring technologies. Home care patients can transmit vital signs like weight, blood pressure, heart rate and blood glucose levels and eliminate the need for a face-to-face visit by a nurse or aide. Using telemedicine tools also can eliminate a face-to-face visit by enabling a home care patient to consult with his or her physician virtually. When face-to-face visits are needed, scheduling technologies can help make visits more efficient from a travel perspective. Also, home health nurses and aides should be able to document their visits onsite and enter patient health information electronically into the EHR system. That eliminates the additional step of entering that information offsite at a later time.

Other than technology, what steps can home health providers take to comply with the new rules?

Lugo: HHAs should invest in training and education. All members of the home health interdisciplinary care team must be educated on the new requirements and trained on how to meet them. Team members must be skilled at assessments, clinical documentation, care coordination, case management, communication with the care team and communication with patients and family. They also should be educated and trained to use new high-tech home health products that improve clinical outcomes and lower costs.

What new high-tech products should home health providers have in their inventory?

Lugo: HHAs should have self-testing equipment in their inventory. That enables nurses and aides to do things like urine and blood testing in the home and eliminates the need for those tests to be done at a clinical lab or in a doctor’s office. A nurse who can do a PT/INR blood test in the home and look at a patient’s blood-clotting level can make a medication change right there on the spot. HHAs also should have high-tech wound dressings in their inventory. Switching to wound dressings that need to be changed once a week versus three times a day promotes healing and lowers the chances of infection. It also trims the HHA’s labor costs by reducing the number of home visits for dressing changes.

Related: Learn more about McKesson’s supplies and solutions for home health

¹ “CMS Finalizes New Medicare and Medicaid Home Healthcare Rules and Beneficiary Protections,” Centers for Medicare and Medicaid Services, 2017

² Medicare and Medicaid Program: Conditions of Participation for Home Health Agencies, Centers for Medicare and Medicaid Services, 2017

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