Comments Submitted on the Changes to Conditions of Participation

LeadingAge NY submitted  comments to the Centers for Medicare and Medicaid Services (CMS) on Wed., Jan.7 regarding the proposed changes in the Conditions of Participation (CoPs) for Home Health Agencies (HHA). The proposed rule (CMS-3819-P) outlines the first major changes to the CoPs since 1989. 

LeadingAge NY conferred with LeadingAge, and discussed overarching concerns which were incorporated in LeadingAge's comments to CMS. Some of the issues that were discussed, include: patient rights; cause for discharge; plan of care; Quality Assessment and Performance Improvement (QAPI); infection control; and contents of the clinical record.

LeadingAge NY submitted additional comments to emphasize issues relevant to New York HHAs. We are pleased to see in the proposed changes the move to modernize the HHA CoPs and have them be more of an outcome-oriented approach. However, we did expressed concern about the proposed regulations not taking in consideration the dramatic changes taking place in the health care delivery system in New York and other states.

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