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CMS Proposed Changes to Home Health Agencies Conditions of Participation (CoPs)

The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule that revises the Conditions of Participation for Home Health Agencies. A fact sheet has been posted which highlights the reasons for the change including focusing on patient rights, enhancing the process for care planning, delivery of services, streamlining regulatory requirements, and building a foundation for ongoing, data-driven quality improvement.

The proposed rule includes:

  • Revisions to OASIS;
  • Expanding patient rights;
  • Focus on holistic patient assessment;
  • Adding a requirement that CHHAs must maintain a system of communication and integration;
  • Adding a new requirement to develop, implement, and maintain an agency-wide QAPI program;
  • Addressing a new infection control requirement;
  • Condensing the requirement for nursing and therapy services into a single requirement that focuses on integrated patient care planning and delivery;
  • Reinforcing HHA supervision requirement;
  • Clarifying the management and administrative structure; and
  • Continuing branch offices but eliminating “subunits.”

LeadingAge NY will analyze the proposed rule and send a detailed analysis to members. Please submit your questions or concerns to us so we can include them in our feedback to LeadingAge and CMS.

Comments are due Dec. 8, 2014.

Contact: Cheryl Udell, cudell@leadingageny.org, 518-867-8871