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The most sweeping changes in the final rule of the CoPs for HHAs fall within the purview of patient rights and QAPI programs. Here’s a closer look at what they entail.
One of the greatest changes in the final rule of the CoPs for HHAs involves the addition of a patient’s bill of rights that must be clear and accessible to both patients and staff. Comprehensive patients’ rights must be clearly enumerated and steps must be taken to ensure their rights are assured.
Under new rules, notification of patients and representatives will be tackled differently. Patient rights will now need to be explained during the evaluation visit, in a manner easily understood by patients and representatives. During the second visit, notification of patient rights must be submitted – free of charge – in writing, so as to be understood by those with limited English proficiency. This means that HHAs will have to enlist the services of interpreters, where necessary and put in place new polices and processes, including staff training to ensure compliance.
Additional documentation to patients and caregivers will also include:
With more patient-centred regulations in place, agencies will now have to take into account patient preferences and prove progress toward each patient’s identified goals.
HHAs will also need to identify family caregivers and their willingness and ability to help provide care.
In many cases, a patient may have different representatives for financial, legal and healthcare decision-making. To ensure compliance HHAs should know the legal scope of patient representatives – distinguishing between a representative and a legally appointed person – and act in accordance with a patient’s choices.
Quality Assessment and Performance Improvement (QAPI)
The QAPI program revisions focuses on a patient-centred, data-driven and outcome-driven, interdisciplinary approach to improve the delivery and quality of patient care while reducing medical errors.
It encompasses five standards including (i) program scope; (ii) program data; (iii) program activities; (iv) improvement projects; and (v) executive responsibilities. The final regulation requires HHAs to “develop, implement, evaluate and maintain an effective HHA-wide, data-driven QAPI program.” It states that a HHA’s QAPI program must be tailored to reflect the complexity of the HHAs organization including all services while focusing on indicators related to improved outcomes including use of emergency services, hospital admissions, and readmissions.
Starting with a true patient-centred assessment, care planning and service delivery model, agencies will need to develop a more integrated care process on a continual basis to encompass all aspects of home health services.
Agencies will need to show data collection and performance projects to demonstrate improvement with the CoPs providing options regarding areas where they can improve care quality and performance. Records will need to reveal contributions of different skilled professionals and show evidence of peer interaction to meet patient needs.
New requirements regarding a patient’s comprehensive assessment will need to include the patient’s:
Based on their level of accreditation, some agencies already meet these requirements, while others will now have to employ people and processes to meet these guidelines. Failure to comply will mean costly fines and may even escalate to suspension of participation in Medicare and Medicaid programs.
While changes in this area will be expensive and require the institution of new systems and staff, the implementation date for this CoP is set for 2018. However it will be wise to get started immediately to develop the required policies, systems, and tools, and also to test the programs to ensure they meet regulation requirements.
Though the new CoPs will impose significant cost and administrative burdens as well as a crunch on the implementation time, the new regulations have been a long time coming. In the long run, the new CoPs will significantly improve patient care and agency performance. On the upside, for those looking for more time, NAHC is currently assessing if the implementation deadline of 6 months is sufficient, having already requested, along with several other agencies a timeline of 12 to 18 months for implementation.
** Get a section-wise summary at: http://www.hallrender.com/2017/01/17/cms-finalizes-new-conditions-participation-home-health-part-1/
**** You can also access the final rule at the Federal Register: https://www.federalregister.gov/documents/2017/01/13/2017-00283/medicare-and-medicaid-program-conditions-of-participation-for-home-health-agencies