By Wes Little, Vice President, WellSky Applied Insights
The new Medicare Conditions of Participation (CoPs), scheduled for implementation January 13, 2018, represent the most significant changes to home health in more than three decades. The CoPs include sweeping changes that will require home health agencies to provide more patient-specific, outcome-oriented, and collaborative care. But with a compliance deadline fast approaching and interpretive guidelines still pending, the preparation needed to successfully deliver this enhanced care will be anything but easy.
Agencies will need to invest significant time and resources to comply with the new CoPs. This dramatic shift will undoubtedly put unprepared agencies out of business, as was the case with major home health rule and reimbursement changes in the past.
Here are the changes we know about now, what they will mean for your business, and how you can adapt to survive and get ahead:
1. Compliance isn’t optional, and it will require significant organizational and process changes.
Home health agencies can’t afford to risk noncompliance, and comprehensive process changes need to be in place prior to January 13, 2018 to avoid penalties. As stated by the National Association For Home Care & Hospice (NAHC):
“Agencies that fail to meet any of the [Conditions of Participation] are at risk, at a minimum, for the imposition of a number of sanctions and potentially at risk for program termination.”
The new CoPs will require increased care management and documentation efforts from your clinical staff. The plan of care will be a primary focus. Backoffice staff will also need to take responsibility for providing more communications to patients. There will inevitably be agencies in your market who do not take heed of these changes and will be forced out of business. By preparing wisely and in advance, your agency can use this historic shift in home health compliance to gain market share and grow your business.
2. The plan of care as you know it will change fundamentally. Under the new CoPs the plan of care must always be current and readily deliverable.
The most comprehensive changes mandated by the CoPs pertain to the plan of care. Soon, simply creating a static 485 at the start of the episode will be insufficient. Under the CoPs, your care plans must be specifically customized to individual patient needs, be both historic and up-to-date (recording both changes over time and showing the most current version), and evolve as the patient’s condition changes. Agencies must now also assess each patient’s hospitalization risk at the start of the episode and include a remediation plan to reduce avoidable admissions and ER visits. This “living, breathing” plan of care will require your agency’s whole team to be cognizant of each patient’s real-time progress toward their unique goals.
Under the new CoPs…
- The plan of care (POC) is a living document, reviewed and signed by the physician Everyone working with a patient must be able to see all versions of the POC
- Agencies must provide patients and their caregivers with any updated written information from the POC in any format the agency chooses (as long as all of the required elements are provided)
- Patients must be notified of POC changes
- Patients must be assessed for hospitalization risk and have a plan to reduce risk
- Agencies cannot discharge a patient except for a few circumstances:
- (1) If the physician responsible for the home health agency (HHA) plan of care and HHA agreed that the HHA could no longer meet the patient’s needs, based on the patient’s acuity; (2) when the patient or payer could no longer pay for the services provided by the HHA; (3) if the physician responsible for the HHA plan of care and HHA agreed that the patient no longer needed HHA services because the patient’s health and safety had improved or stabilized sufficiently; (4) when the patient refused HHA services or otherwise elected to be transferred or discharged (including if the patient elected the Medicare hospice benefit); (5) when there was cause; (6) when a patient died; or (7) when the HHA ceased to operate.
3. Your team your will need to be more collaborative than ever before.
Medicare’s new CoPs reinforce that home health care must be both a team effort on behalf of the patient and a key stepping stone in a patient’s care journey to self-sufficiency. Home health agencies will be required to communicate plan of care changes to the physician and all the members of the patient’s clinical team, which now must include home health aides.
Upon the patient transfer or discharge, your organization will now be required to develop a comprehensive summary with information about the care you provided and your recommendation for follow-up care. This summary must be sent to the patient’s primary practitioner or the health care professional responsible for the patient’s care after discharge or transfer from your home health agency.
This interdisciplinary and communicative approach should be at the heart of your organization’s clinical culture, and your whole team must be committed to making this change. Successful team collaboration will strengthen long-term relationships with key referring physicians and ensure ongoing patient flow and business growth in the future.
Under the new CoPs…
- The POC needs to be communicated to other physicians
- Home health aides must be on the interdisciplinary team and must report changes in the patient’s condition
- The Comprehensive Discharge & Transfer Summary must include:
- The initial reason for home health services
- A description of patient’s care
- A description of the patient’s complete status at the start and end of care
- The most recent drug profile
- The recommendation for follow-up care
- The completed discharge summary must be sent to the physician within five days
4. You will need to empower your patients with information as part of new patient rights and communications updates.
Another potentially challenging aspect of the new CoPs is the requirement for new, formal communication with patients and their representatives. In an effort to more actively involve patients in their own recovery, CMS will require that agencies will now provide each of their patients with updated information about their care as their episode progresses. These comprehensive communication changes will require significant administrative efforts from your team.
Under the new CoPs…
- Patients must receive a verbal notice of patient rights by second visit and a written copy within four days of evaluation
- Written information provided to the patient includes the patient’s schedule, frequency, medications, treatments, other pertinent instructions, and the name and contact information of the agency’s clinical manager (a new required role)
- Agencies must collect contact information for the patient and the patient’s representative
- Clinical records (hard copy or electronic) must be available to the patient, upon request at the next home visit or within four business days
- Each patient needs an individualized emergency plan
- Patients must receive information about how to submit a complaint
5. It’s critical that your electronic medical record (EMR) software has the foresight and agility to support CoPs compliance.
Making the fundamental organizational changes to comply with the new CoPs will be hard enough for all home health agencies, and your software shouldn’t make it harder. Even with these sweeping changes, Kinnser Software customers will be prepared because they use a software that has been designed for compliance.
Kinnser has been working towards this change for years with innovative product developments including:
- Kinnser RiskPoint® — A data-driven tool that proactively assesses rehospitalization risk
- Kinnser Physician Access™ — A collaborative web-based tool that allows physicians to conveniently make online referrals and sign orders in real time
- And coming soon, Kinnser Progress to Goals™ — the latest advancement in clinical documentation that supports patient-specific and measurable goal-writing
All of these innovative features are available in Kinnser Agency Manager® — the industry’s most widely used home health software.
As the CoPs evolve, Kinnser continues to develop solutions and updates to help customers comply with the challenges ahead. While there will always be some manual tasks that must be done outside of your software system, Kinnser automates tasks that, in other systems, require hours of tedious, repetitive work to accomplish. Kinnser customers have the competitive advantage of using one of the most innovative and fast-developing products on the market.
Customer success and growth is our top goal as a company. We are committed to helping our customers deliver exceptional care, stay in compliance with the new CoPs, and succeed as sustainable, profitable businesses.
Learn more about Kinnser Software and our full suite of innovative care solutions for home health: Kinnser Agency Manager: The Complete Home Health Software Solution