CMS Releases Final Interpretive Guidance for Home Health Agencies
On January 13, 2017, the Centers for Medicare and Medicaid Services (CMS) published the revised Conditions of Participation (CoPs) for Home Health Agencies (HHAs), 42 CFR 484, Subparts A, B, and Subpart C. The new CoPs were released with an effective date of July 13, 2017. The effective date was subsequently delayed until January 13, 2018.
CMS issued draft Interpretive Guidelines in January 2018, however clearance of the final interpretive guidance document was delayed. CMS has now released the final Home Health Agency Interpretive Guidelines; there are no significant changes from the draft guidance in this final document.
Highlights from the revised CoPs include:
- A comprehensive patient rights condition of participation that clearly enumerates the rights of home health agency patients and the steps that must be taken to assure those rights.
- An expanded comprehensive patient assessment requirement that focuses on all aspects of patient wellbeing.
- A requirement for an integrated communication system that ensures that patient needs are identified and addressed, care is coordinated among all disciplines, and that there is active communication between the home health agency and the patient’s physician(s).
- An expanded patient care coordination requirement that makes a licensed clinician responsible for all patient care services, such as coordinating referrals and assuring that plans of care meet each patient’s needs at all times.
Included with today’s notice are example policies reflecting the revised Home Health CoPs as well as a link to the final Interpretive Guidance. For additional resources see MCN Healthcare’s Home Health Policy and Procedure Manual.
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