Home Health & Hospice Articles by Topic: Conditions of Participation

Consider best practice for aide competency after CoP updates

• Homecare Direction, Issue 11, November 8, 2019

  Agencies should take a close look at how they conduct competency evaluations to ensure compliance...

Changes to verbal rights notification finalized, don't lose sight of requirements

• Homecare Direction, Issue 11, November 8, 2019

  Agencies will no longer be required to provide patients with a verbal notification of all their...

Pseudo-patients now greenlighted for aide competency evaluations

• Homecare Direction, Issue 10, October 11, 2019

  Agencies once again will be able to use pseudo-patients to conduct aide skill competency...

New discharge planning CoP for home health not as burdensome as proposed

• Homecare Direction, Issue 10, October 11, 2019

  After four years, a proposed rule and a deadline extension, CMS is finalizing conditions home...

If a patient has a significant change in the middle of the first 30-days period, does a new plan of care have to be submitted, and what are recommendations for coding with that?

• Homecare Q&A, Issue 8, August 26, 2019

  It depends on the agency’s policy but if the patient’s change is really significant...

Is there a specific home care condition requiring home health agencies to provide opioid education to all patients?

• Homecare Q&A, Issue 7, July 29, 2019

  There is no opioid specific education related to the revised Home Health Conditions of...

Should we code all diagnoses or only those affecting the plan of care?

• Homecare Q&A, Issue 7, July 29, 2019

  Unfortunately this is an instance of where we have conflicting regulations.

Is it allowable to bill without a signed consent to treat and a signed benefit form?

• Homecare Q&A, Issue 7, July 29, 2019

  Since this is a condition for payment, then the patient must give informed consent prior to...

Don't let OASIS-D1 changes reduce the quality of your comprehensive assessments

• Homecare Direction, Issue 7, July 8, 2019

  While OASIS-D1 will make responses to 23 existing items optional, agencies must keep in mind that...

Should we use a risk assessment form for hospitalizations?

• Homecare Q&A, Issue 4, April 18, 2019

  I don’t like adding extra forms and paperwork for staff.  

Thoughts on CMS' proposed rule to alleviate burden and when it will be finalized?

• Homecare Q&A, Issue 4, April 18, 2019

  A couple years ago, the new administration came in with a desire to simplify life for providers.

In the coming year, how do you think survey targets will change?

• Homecare Q&A, Issue 4, April 18, 2019

  We’re going to keep seeing agencies cited for issues involving organization and...

Many agencies identify timely initiation of care as a key PIP for 2019

• Homecare Direction, Issue 4, April 8, 2019

  Education and communication are the keys to improving timely initiation of care for agencies...

How can we keep our eyes on the ball on hospitalizations as we move to the next PIP?

• Homecare Q&A, Issue 3, March 22, 2019

  Root cause analysis still needs to be done at every hospital transfer because agencies will be able...

Must PIPs include a representative of all disciplines, a physician and a consumer like the PAC?

• Homecare Q&A, Issue 3, March 22, 2019

  The revised CoPs don't give specific protocols for what a PIP must look like.

Is the board responsible to sign off on all policies? 

• Homecare Q&A, Issue 3, March 22, 2019

  The Home Health Conditions of Participation (CoPs) require the governing body approve all policies...

How can I decrease the number of clinician missed visits? How do Medicare surveyors treat missed visits?

• Homecare Q&A, Issue 3, March 22, 2019

  Are the clinicians moving the visits to another day during the week?

Any advice for best practices to add emerging infectious diseases into emergency prep?

• Homecare Q&A, Issue 2, February 25, 2019

  You note that CMS is adding “emerging infectious diseases” to the current definition of...

When a patient signs a paper form (consent for care, AOB, ABN, etc.) are we required to keep the actual signed form if we have a picture of the signed form in our electronic medical record?

• Homecare Q&A, Issue 2, February 25, 2019

  When the revised Home Health Conditions of Participation (CoPs) originally came out, there was an...

In the QAPI requirement §484.65, what does CMS mean by including the prevention and reduction of medical errors?

• Homecare Q&A, Issue 2, February 25, 2019

  We are assessing and observing if we have an issue related to medical error.

Reducing hospitalization rates will be a key goal for many agencies in 2019

• Homecare Direction, Issue 2, February 5, 2019

  More agencies plan to focus on improving the rate of acute care hospitalizations than any other...

For PDGM, agencies will need to change how they handle case conferencing

• Homecare Direction, Issue 2, February 5, 2019

  Case conferences will take on increased importance when the Patient-Driven Groupings Model (PDGM...

What about the F2F requirements? Should we treat all payers the same and require the same as Medicare?

• Homecare Q&A, Issue 1, January 16, 2019

  Face to Face is a Conditions of Payment requirement and is required for Medicare and Medicaid.

What is G1024 (Authentication) and how can agencies avoid getting cited for it?

• Homecare Q&A, Issue 1, January 16, 2019

   G1024 (Authentication) is one of the more common standard-level deficiencies in 2018.

CMS gives itself one-year extension to publish a new discharge planning rule

• Homecare Direction, Issue 12, December 5, 2018

  CMS has just given itself an additional year — until Nov. 3, 2019 — to finalize its...

Proposed rule seeks to change CoPs, eliminating burden for agencies

• Homecare Direction, Issue 10, October 4, 2018

  CMS is proposing to eliminate three requirements it has deemed “burdensome” for home...

Long-awaited final interpretive guidelines provide clarification about the revised CoPs

• Homecare Direction, Issue 10, October 4, 2018

  Nearly eight months after the revised Home Health Conditions of Participation (CoPs) took effect...

Can you give pointers on "environmental cleaning and disinfection" as mentioned in draft guidelines for the revised CoPs?

• Homecare Q&A, Issue 13, September 4, 2018

  You should have a policy in place that describes things like a bag barrier and how to clean your...

Can you explain in this scenario whether our surveyor is correct and what our agency should do?

• Homecare Q&A, Issue 13, September 4, 2018

  In the scenario you discuss, your agency is in Indiana and are currently going through a federal...

Review your emergency preparedness - it's a top target on surveys in 2018

• Homecare Direction, Issue 7, July 2, 2018

  Among the top 12 standard-level deficiencies in home health thus far in 2018, seven involve issues...

Prioritize areas for improvement, have your next target QAPI project identified

• Homecare Direction, Issue 7, June 29, 2018

  It’s great if your agency’s performance improvement project (PIP) under QAPI is up and...

CMS surveyors appear to be targeting issues involving aide training, supervision

• Homecare Direction, Issue 6, June 4, 2018

  Initial survey results following the implementation of the revised Home Health Conditions of...

Do we need to enumerate one by one the patient?s rights over the phone to the legal representative?

• Homecare Q&A, Issue 9, May 12, 2018

  This can be done by electronic methods.

What is the best way to comply with the patient rights requirement?

• Homecare Q&A, Issue 9, May 12, 2018

  Several agencies have provided this information through a secure portal either through their EMR or...

Early survey results show individualized plans of care are a major target

• Homecare Direction, Issue 5, May 2, 2018

  Break your agency’s clinicians of their mentality to rely solely on generic language or...

Early survey results reveal patient rights as target areas under revised CoPs

• Homecare Direction, Issue 5, May 2, 2018

  Key target areas include informing patients about visit frequency and about explaining financial...

Ensure aides conduct competency testing on patients or take a bath on surveys

• Homecare Direction, Issue 4, April 12, 2018

  Take steps to ensure the small pool of home health patients you have who can or do bathe would...

Train intake to gather more detail, ensure patient rights process is efficient

• Homecare Direction, Issue 4, April 12, 2018

  To help comply with the new patient rights requirements in the revised Home Health Conditions of...

New online training for surveyors highlights the importance of a detailed plan of care

• Homecare Direction, Issue 3, March 29, 2018

  CMS’ newly posted surveyor training reiterates the need for home health agencies to ensure...

What should we have done to help us comply with the new CoPs?

• Homecare Q&A, Issue 5, March 5, 2018

  If you haven’t done so already, do the following to help your agency tackle compliance with...

In regards to the probe-and-educate review, what will Medicare Audit Contractors (MAC) target?

• Homecare Q&A, Issue 5, March 5, 2018

  In CMS’ targeted probe-and-educate review, MACs will send ADRs to agencies that...

Home Health Quality Reporting Program: Revised logic for the Timely Initiation of Care measure

• Homecare E-News, Issue 10, March 5, 2018

  The Medicare Conditions of Participation (CoPs) for home health agencies that became effective...

Tip: Review the Statement of Deficiencies carefully

• Homecare E-News, Issue 9, February 26, 2018

  After a CMS survey, the home health agency administrator, clinical manager, and any other key...

CMS provides surveyors a high-level overview of the revised Home Health CoPs

• Homecare Direction, Issue 2, February 5, 2018

  Experts fear a lack of detailed surveyor training from CMS on the revised Home Health Conditions...

CMS releases new memo detailing tags for use with revised Home Health CoPs

• Homecare E-News, Issue 4, January 22, 2018

  CMS has sent a memo to state survey agency directors about the new tags surveyors should use to...

What do we need to consider in terms of the new infection control CoPs?

• Homecare Q&A, Issue 2, January 17, 2018

  Review agency policies and procedures around infection control and update them.

Should we be using the draft interpretive guidelines for compliance?

• Homecare Q&A, Issue 2, January 17, 2018

  You should review the final CoPs and the draft interpretive guidelines.

CoPs will impact operations, financials more than any other requirement in 2018

• Homecare Direction, Issue 1, January 8, 2018

  Within the revised Home Health Condi-tions of Participation (CoP) slated to take effect January...

CMS: CoPs' effective date won't change regardless of when final IGs are released

• Homecare E-News, Issue 2, January 8, 2018

  The final interpretive guidelines for the revised Home Health Conditions of Participation (CoPs...

Understanding the need for translation services ? required in the CoPs

• Homecare E-News, Issue 48, December 18, 2017

  When examining the new draft guidelines for the revised Home Health Conditions of Participation...

Prepare for new CoPs: Draft interpretive guidelines for the CoPs answer some questions, create others

• Homecare Direction, Issue 12, December 11, 2017

  CMS’ long-awaited draft version of the interpretive guidelines for the revised Home Health...

We are looking for translation services. What should we consider when hiring a vendor?

• Homecare Q&A, Issue 23, December 1, 2017

  Agencies that have never used a translation service before should investigate their options right...

How do we challenge our survey?

• Homecare Q&A, Issue 23, December 1, 2017

  Regardless of whether you determine to challenge a survey, the Plan of Correction must be...

CMS releases new guidance about subunits

• Homecare E-News, Issue 45, November 27, 2017

  CMS has issued new guidance that explains how agencies can go about converting subunits to...

Industry stakeholders seek clarity from CMS about draft interpretive guidelines.

• Homecare E-News, Issue 45, November 27, 2017

  Many agencies are expressing deep concern about the lack of detail — and confusing details...

CMS decides to delay civil monetary penalties for revised CoPs

• Homecare E-News, Issue 44, November 20, 2017

  CMS has decided to wait a year from Jan. 13 before imposing civil monetary penalties involving the...

TJC approves revised standards in advance of CMS' emergency prep requirement

• Homecare E-News, Issue 43, November 13, 2017

  After CMS review, The Joint Commission has finally prepublished revisions to the Emergency...

Update coordination of care, plan of care practices to comply with new CoPs

• Homecare Direction, Issue 11, November 2, 2017

  Restructure clinical managers’ positions so they function more like case managers. Doing so...

Is there a regulation that states that RNs cannot trim the toenails of a patient with diabetes?

• Homecare Q&A, Issue 21, November 2, 2017

  A nurse should be skilled in cutting toenails, but because of the increased risk of liability if...

Where is it specifically written that an NP or a PA cannot sign homecare orders?

• Homecare Q&A, Issue 20, October 17, 2017

  There is no language specifically stating an NP or PA cannot give orders. Rather, the rules...

If I was to leave this job, do I still qualify as an administrator for home health under the new home health CoPs or am I just grand fathered in under the old rule because I have held this position (my current position)?

• Homecare Q&A, Issue 19, October 3, 2017

  Yes, the personnel qualification requirements for HHA administrators at §484.115(a) will...

Protect patients during hurricanes by identifying their need for immediate care

• Homecare Direction, Issue 10, October 2, 2017

  The way Texas and Florida agencies reacted to the recent catastrophic hurricanes should serve as a...

What happens when a CMS survey begins?

• Homecare Q&A, Issue 17, August 31, 2017

  The moment an HHA considers to be the start of the survey is when the surveyor arrives...

We use a set of hospice standing orders when a patient is admitted to hospice. How can we show individualization with this, in order to comply with regulations?

• Homecare Q&A, Issue 17, August 31, 2017

  Interpretive Guidelines §418.56(c)(2) state...

MAC spokesman: Probe-and-educate review has high error rate, could expand

• Homecare Direction, Issue 8, August 25, 2017

  Two months after CMS said there was no plan for another round of the probe-and-educate review for...

Create a patient rights verification form to prevent survey citations related to revised CoPs

• Homecare Direction, Issue 8, August 14, 2017

  Create a checklist to verify that your agency has explained to patients and/or their legal...

New emergency preparedness guidelines provide clues for what surveyors will focus on

• Homecare Direction, Issue 7, July 21, 2017

  Review emergency preparedness policies and procedures at least annually, and make sure they...

When can we expect to see interpretive guidelines? What should our agency be doing given the new CoP delay?

• Homecare Q&A, Issue 14, July 17, 2017

  The clock has been reset, and agencies that haven’t taken steps to prepare for the revised...

CMS finalizes home health CoP delay days before effective date

• Homecare E-News, Issue 26, July 10, 2017

  Less than a week before most of the revised Home Health Conditions of Participation (CoPs) were...

Implement a strong performance improvement project as part of QAPI

• Homecare Direction, Issue 7, July 10, 2017

  Your agency has gone through the quality assessment piece of QAPI and identified areas that need...

Final Home Health CoPs: Minimize the cost of compliance

• Beacon Institute On-Demand Webcast Library, Issue 2, February 22, 2017

  Final Home Health CoPs: Minimize the cost of compliance

What does the summary report on the clinical record need to entail?

• Homecare Q&A, Issue 14, July 17, 2016

  The Conditions of Participation (CoP) mandate the agency to send a summary report to the physician...

What do the proposed Conditions of Participation (CoP) change in terms of general provisions?

• Homecare Q&A, Issue 10, May 17, 2016

  Under the General Provisions, there are several proposed changes, including: Subunits will be...

I just learned I'm in one of the nine states required to abide by value-based purchasing (VBP)! What do I need to know?

• Homecare Q&A, Issue 6, March 18, 2016

  I just learned I'm in one of the nine states required to abide by value-based purchasing (VBP...

What do the CoPs say about Lovenox administration?

• Homecare Q&A, Issue 4, February 18, 2016

  I work at a homecare agency, and we have been getting referrals lately for nurses to administer...

Can you explain CMS’ proposed Conditions of Participation as they relate to patient rights?

• Homecare Q&A, Issue 3, February 3, 2016

  CMS has made it clear it is looking to ensure patient rights are respected and expanded with much...

Can we accept physician verbal orders to begin home health services?

• Homecare Q&A, Issue 22, November 17, 2015

  We are seeking clarification on whether we can accept a physician’s verbal order to begin...

Weekly Roundup

• Homecare E-News, Issue 44, November 9, 2015

  On Monday, November 2, the Department of Health and Human Services (HHS) Office of Inspector...

Inside Story | The role of the care plan and visit notes in maintaining a compliant clinical record

• Homecare E-News, Issue 43, November 2, 2015

  The written care plan is not simply busywork. It is essential in the organization, delivery...

If the patient does not require a skilled bath, can our agency continue to provide this under the state personal care program?

• Homecare Q&A, Issue 19, October 2, 2015

  If the patient does not require a skilled bath, can our agency continue to provide this under the...

Can you please explain what specifically needs to be under the supervisions of licensed professionals?

• Homecare Q&A, Issue 19, October 2, 2015

  Can you please explain what specifically needs to be under the supervisions of licensed...

How do we update the comprehensive assessment for a major deterioration in status with the PPS payment requirements?

• Homecare Q&A, Issue 18, September 17, 2015

   This patient’s change in condition has a real impact on resource utilization—an...

What does a comprehensive assessment include for non-OASIS patients, according to the Conditions of Participation (CoP)?

• Homecare Q&A, Issue 18, September 17, 2015

  The CoPs identify several key components for this assessment. Here are the components and some...

I have read that CMS in 2015 has added to the Medicare manual that physicians need to estimate how much longer the skilled services will be required. Is there any clarification on this, and are we seeing any claims being denied due to this?

• Homecare Q&A, Issue 14, July 16, 2015

  According to the final rule for 2015, physicians must state the length of skilled services for...

Where can I find that it would be illegal to charge a Medicare home health patient prior to rendering services, while reimbursing patient once CMS has paid the claim?

• Homecare Q&A, Issue 12, June 15, 2015

  Assignment of benefits - This term means that the facility or the physician agrees to accept...

What does Patient Care 484.60: Care Planning, Coordination of Services and Quality of Care mean for agencies?

• Homecare Q&A, Issue 8, June 9, 2015

   First, let’s review for everyone reading what the current CoP is and what is being...

If the physician orders vital signs, blood sugar monitoring, and/or pulse oximetry, do we need acceptable parameters on the plan of care?

• Homecare Q&A, Issue 11, June 3, 2015

  If the physician orders vital signs, blood sugar monitoring, and/or pulse oximetry, do we need...

Can we accept orders from a physician?s secretary or office nurse who is communicating with us instead of the physician?

• Homecare Q&A, Issue 11, June 3, 2015

  Can we accept orders from a physician’s secretary or office nurse who is communicating with...

What do we do if a patient has been snatched away from us?

• Homecare Q&A, Issue 11, June 3, 2015

  What do we do if a patient has been snatched away from us?

How can extended daily visits be justified and covered?

• Homecare Q&A, Issue 10, May 17, 2015

  How can extended daily visits be justified and covered?

Where can I find the rule about physician cosigning of a nurse practitioner's order so the order is valid?

• Homecare Q&A, Issue 10, May 17, 2015

  Where can I find the rule about physician cosigning of a nurse practitioner’s order so the...

Where is it specifically written that an NP or a PA cannot sign homecare orders?

• Homecare Q&A, Issue 10, May 17, 2015

  Where is it specifically written that an NP or a PA cannot sign homecare orders?

Can we use "zero" as a frequency in writing physician orders?

• Homecare Q&A, Issue 10, May 17, 2015

  Can we use “zero” as a frequency in writing physician orders? For example, physical...

What should you do about a tardy recertification assessment?

• Homecare Q&A, Issue 10, May 17, 2015

  What should you do about a tardy recertification assessment?

If a RN sees a patient on Monday, April 13, 2015, when is the next supervision visit due?

• Homecare Q&A, Issue 10, May 15, 2015

  If a RN sees a patient on Monday, April 13, 2015, when is the next supervision visit due? I...

What does the proposed standard Patient Care 485.65: Quality Assessment & Performance Improvement mean for my agency?

• Homecare Q&A, Issue 9, May 3, 2015

  My agency has been reviewing the proposed Conditions of Participation (CoP). We are looking at the...

What should you do about a tardy recertification assessment?

• Homecare Q&A, Issue 9, May 3, 2015

  What should you do about a tardy recertification assessment? It’s the fifth day of the...

Can we get an MD order for a new start of care (SOC) date based on the patient request?

• Homecare Q&A, Issue 9, May 3, 2015

  Regarding M0102 and M0104: We received a referral and we contacted the patient within the...

Is a patient who is toileted every two hours covered under Medicare?

• Homecare Q&A, Issue 6, March 17, 2015

  In combination, the nurse and HHA can provide up to 35 hours a week in medically necessary...

Is it true that we need to change our process and submit ALL OASIS assessments to the AS

• Homecare Q&A, Issue 6, March 17, 2015

   Yes, all Medicare, Medicare Advantage, and Medicaid OASIS assessments must be transmitted.

Is it true that the physical therapist has to make a visit no less than once every two weeks when a physical therapy assistant is involved with the same case and primarily doing most visits?

• Homecare Q&A, Issue 5, March 3, 2015

  On the federal level, the CoPs/ Medicare Benefit Policy Manual states that for all certified...

Is there a requirement to have our annual program review/PAC minutes approved by our board of directors each year?

• Homecare Q&A, Issue 5, March 3, 2015

  There is not a specific Condition of Participation (CoP) stating that the board must review your...

Will home health remain exempt from overtime compensation in most circumstances like it has for 40 years?

• Homecare Insider, Issue 1, January 5, 2015

  Will home health remain exempt from overtime compensation in most circumstances like it has for 40...