CMS Extends Compliance Date for New Home Health Conditions of Participation

conditions of participation home health agenciesThe Centers for Medicare & Medicaid Services (CMS) has proposed that the effective date of new Conditions of Participation for Home Health Agencies (CoP)be delayed.  The original effective date of the new regulations was July 13, 2017.  The recently proposed rule would delay the effective date of the new CoP until January 13, 2018.

The new CoP were published in January of this year and were the first major revisions made to the rules in nearly 20 years.   The new rule reflects an increased focus on a patient centered, data-driven, outcome-oriented process that continually promotes high quality patient care at all times. The regulations represent a move away from regulatory focus on enforcement of prescriptive health and safety standards toward improving the quality of care for all patients.  Regulatory priorities are more focused on stimulating broad-based improvements in quality of care rather than expending resources on enforcing standards against marginal providers.

The new regulations purport to permit greater flexibility in how home health agencies are permitted to meet quality standards.  The new focus stresses interdisciplinary patient care and aims at creating broad-based measurable improvements in quality of care while streamlining procedural burdens that impede providers.

A few areas of change include new requirements for:

  • More continuous, integrated care process across all aspects of home health services, based on a patient-centered assessment, care planning, service delivery, and quality assessment and performance improvement.
  • Use a patient-centered, interdisciplinary approach that recognizes the contributions of various skilled professionals and their interactions with each other to meet the patient’s needs.
  • Emphasis on quality improvements by incorporating an outcome-oriented, data-driven, quality assessment and performance improvement program specific to each HHA.
  • Eliminate the focus on administrative process requirements that lack adequate consensus or evidence that they are predictive of either achieving clinically relevant outcomes for patients or preventing harmful outcomes for patients.
  • A focus on safeguards on patient rights.

The extension of the effective date for the new regulations responds to concerns that were voiced by industry groups that there would be difficulties meeting the required timeline for implementing new quality assessment and improvement requirements.

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