How one hospital prepared for the new home health conditions of participation

May 29, 2018 |  Home Care, Government Regulations

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The latest Home Health Conditions of Participation (CoPs) that went into effect on Jan. 13 have been making waves across our industry. These updated CoPs — standards that agencies must meet in order to participate in Medicare — included several completely new regulations, as well as revisions to many others. And despite the fact that CMS (Centers for Medicare & Medicaid Services) delayed the phase-in date of the new standards, many agencies had to scramble to prepare in time. 

Debbie Albaugh, home health care director of Union Hospital (Dover, OH), was one executive who embraced the changes, and was ready when Jan. 13 came around. She recently shared some tips with me, on preparing for and adhering to these new regulations.

Facing comprehensive changes like these, it can be difficult for home care agencies to know where to start. How did Union begin the process of preparing for these new regulations?

Debbie Albaugh: For us, starting early was key. As soon as the draft form of the CoPs came out, we began developing processes to meet the new regulations, implementing the ones that we could. That way, when the drafts were finalized, we were already well underway.

I try to be very organized, and I built an Excel spreadsheet around the different conditions and standards, making note of the ones that we were and weren’t meeting at the time. Our team met internally on a weekly basis, and I attended some webinars and daylong workshops so I would be thoroughly prepared.

How did your organization need to alter its workflows to comply with the new regulations?

Albaugh: There were some brand new requirements that we needed to make alterations for. For example, we’ve revised our intake process so that the patient is always asked if they need an interpreter and if they have a legal representative. We now have to identify patient-selected representatives, which MEDITECH has added to the patient overview.

Another new requirement: when we receive orders from an MD other than the patient’s primary care physician, (surgeons, for example) we need to notify all physicians of all changes made to a patient’s plan of care. We now send a summary to the PCPs and other ordering physicians, so they can keep track of what’s happening with their patients.

Before, we had manual processes in place to track a patient’s primary physician for home health. Now, in the Track Orders page that was built into the MEDITECH Home Care software, the receiving MD is on the order and can immediately see who the PCP for that patient is. This has dramatically reduced the time that staff spends searching in the system for this information.

What has the response from providers been like?

Albaugh: One of our biggest concerns was that these new CoPs would overwhelm clinicians, perhaps to the point where they’d decide to leave home health altogether. We were fortunate that we didn’t experience a lot of turnover. We tried to solicit staff feedback as much as possible and give them choices when and where we could.

And what about the response from patients?

Albaugh: The intent of these new regulations is to improve the quality of care and home care in particular — to return the focus to the patient. But to be honest, most of our patients don’t seem to even notice the changes. Union has done well with quality outcomes, and these new regulations aren’t having a significant impact on that aspect of our operations. One of the new standards mandates that we develop, implement, evaluate, and maintain a formalized Quality Assurance and Performance Improvement (QAPI) plan, but we were doing that in a modified manner anyway.

How did you ensure that your software was up-to-date when preparing for the new CoPs?

Albaugh: We were in constant communication with MEDITECH throughout this process. If we needed anything that wasn’t in place in our software, the team at MEDITECH built it in for us. MEDITECH made a lot of our requested changes that made it easier for staff to go in and document without having to seek workarounds.

For example, since agencies now need to indicate each patient’s selected representative, MEDITECH responded proactively by adding this to the patient overview in their Home Care software.

Have the new regulations resulted in any new additions to your staff?

Albaugh: There’s a new clinical manager role, to ensure that patient-selected representatives are notified of any changes to the patient’s status and can oversee interactions between different disciplines, both of which are new CoPs mandates.

We’ve reassessed our visit weights and with the new requirements for admissions, we increased a new admission visit to be worth three units. It was two units in the past. 

What are your peers at other organizations saying about the new regulations? How prepared would you say that Union was in comparison to others?

Albaugh: I’ve spoken to several organizations, some that called me back in January looking for my help. A common place where they were running into problems was with their EHR software. In some cases, the software wasn’t being updated in a timely manner and they weren’t getting the vendor assistance that they needed to alter their software to comply with the new regulations. That certainly wasn’t a problem for us.

What advice do you have for organizations that are struggling to comply with these new regulations?

Albaugh: You can’t change everything at once. Focus on breaking the changes down into manageable bits and starting with the easy changes first. Make sure that your staff is ready for survey visits by posting a QAPI plan and an emergency preparedness plan.

Surveyors will want to know that these plans are in place, and that the staff has been educated. We also reinforce staff knowledge of these new regulations by including CoPs items on the agenda of our weekly staff meetings.

Want more information on CoP preparedness? Download MEDITECH’s home care audit guide checklist for the tools you’ll need to ace your next survey visit.

Download the Home Care Audit Guide Checklist

Written by Josh Lamkin, Senior Analyst, Regulatory Compliance, MEDITECH

As a Senior Analyst of Regulatory Compliance, Josh Lamkin monitors, analyzes, and reports on state, federal, and international laws and regulations, industry standards, guidance documents, and federal and state regulatory work groups to ensure MEDITECH meets all regulatory standards. He works to communicate regulatory requirements as well as client requests and recommends action that MEDITECH should take accordingly. Josh is also involved in education initiatives for both clients and MEDITECH staff to ensure widespread awareness and understanding of regulatory requirements.