Home Health & Hospice

Surveyors Pay Attention to PAC

Homecare Insider, December 7, 2009

As your agency wrestles with the new requirements for OASIS and prepares for the Recovery Audit Contractors, remember to check your agency’s compliance with other requirements in the Conditions of Participation.  History has taught us that surveyors tend to focus on the Professional Advisory Committee (PAC).  Consider this question.  

What are the requirements for the composition of the PAC?  Our surveyor stated we had to have representation from all disciplines.  We have nursing and occupational therapy sitting on the committee but physical therapy, speech-language pathology, medical social services, and home health aide services are not represented.

The Conditions of Participation say that the PAC must include “appropriate representation from other professional disciplines.”  However, there is no definition of “appropriate.”  For the surveyor, “appropriate” includes all disciplines.  The agency’s definition appears to be two of six disciplines.  We suspect that “appropriate” falls somewhere in between.  

When the regulations do not define a term, it’s important for the agency to develop a definition.  To determine what’s appropriate, look at the numbers of staff, visits, and patients associated with each discipline.  If the agency employs one part-time speech-language pathologist, he or she may not need to sit on the committee.  It’s also likely that there are not many visits.  A therapy manager could represent that discipline and the committee must address any concerns.  It’s probably also a good idea to have representation for home health aide services.  

“Guidelines for the Professional Advisory Committee” informs the members of your Professional Advisory Committee what they need to know to fulfill their responsibilities.  Click here to learn more.