Last week, VNAA submitted to CMS comments on the proposed Home Health Conditions of Participation. In general, VNAA agrees with the need for updated CoPs for home health agencies (HHA) and the Centers for Medicare and Medicaid Services' (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. Our primary concern relates to the sharing of clinical summaries when a patient is either discharged or transferred to the care of another provider.
VNAA and its members strongly support CMS' efforts to improve care coordination, including through the sharing of clinical records. However, VNAA noted the challenge HHAs may have to comply with the proposed regulations in instances of unplanned transfers during which the HHA is not immediately notified when the patient moves from the home to another care setting. We recommended several modifications to the proposed regulations that will better ensure that providers engaged in the patient's care have the most complete and up-to-date information on the patient. More details on these and other comments are included in the comment letter to CMS.