Final Home Health Conditions of Participation Move Closer to Release
Tuesday, May 10, 2016
by: Visiting Nurse Associations of America

Section: Public Policy and Advocacy

On May 6, the final Home Health Conditions of Participation (CoPs) took one more step toward their release when they were sent to the Office of Information and Regulatory Affairs (OIRA) for review.
In October 2015, the Centers for Medicare and Medicaid Services (CMS) issued its proposal to modernize the home health regulations for the first time since 1989. The proposed CoPs placed a focus on patient-centered, well-coordinated care and included the following updates:
  • A clear explanation of patient rights, including a requirement to communicate with patients in a language and manner that they understand and a requirement that home health agencies must take measures to assure and protect those rights.
  • An expanded comprehensive patient assessment requirement that focuses on all aspects of patient well-being.
  • An integrated communication system—increasingly enabled by health information technology—that ensures that patient needs are identified and addressed, that care is coordinated among all disciplines and that there is active, timely, needs-based communication between the home health agency and the physician.
  • A data-driven, agency-wide quality assessment and performance improvement program that continually evaluates and improves agency care for patients.
  • 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.
VNAA submitted comments to CMS on the proposed CoPs in January 2015. In general, VNAA agreed with the need for updated CoPs and CMS’ emphasis on high quality, patient-centered and safe care. 

Many of the changes proposed in the regulation align with recommendations that VNAA and its members have long-supported. However, VNAA expressed concerns to CMS on several provisions and sought additional clarification on others. Of primary concern was the sharing of clinical summaries when a patient is either discharged or transferred to the care of another provider.
We will continue to monitor the progress of the updated CoPs and provide updates as they are made available. 
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