Thousands of home health providers attended the first webinar in the Home Health Conditions of Participation: Charting a Course for Your Success series. Presented by renowned educators Sharon Harder, president of C3 Advisors and Jill Dyer, BSN, RN, HCS-D, HCS-O, consultant with J.I.D. Consulting & Coding, the webinar provided a thorough introduction to the new CoPs.
This webinar, which was described by attendees as “excellent and super useful” and “one of the most informative and well-presented webinars I have attended,” is now available for viewing on-demand at kinnser.com/cops.
Highlights from Webinar 1:
• The effective date for the new CoPs is now January 13, 2018.
• An exception is the Emergency Preparedness Rule, which takes effect November 15, 2017.
• The interpretive guidelines and changes to the State Operations Manual (SOM), Appendix B are still pending.
• Compliance with the new conditions will be mandatory.
What’s In, What’s Out:
• There are two new Conditions of Participation: 1) Quality Assessment and Performance Improvement (QAPI) and 2) Infection Prevention and Control.
• Three requirements have been eliminated: 1) subunits will no longer be recognized, 2) the Professional Advisory Committee (PAC) will be eliminated along with quarterly record reviews, and 3) the 60-Day Summary will no longer be required.
• An administrator hired following the effective date (January 13, 2018) must be a licensed physician, registered nurse or person with training and experience in health service administration with at least one year of supervisory experience and a minimum of an undergraduate degree.
• Current administrators are grandfathered relative to the qualification requirements.
The New Role: Clinical Manager:
• Coordinates patient care assignments and referrals
• Assures that patient needs are continually assessed and met
• Assures that care plans are individualized and continually updated
• Must be available during all operating hours
• Must be a licensed physician, physical therapist, speech-language pathologist, occupational therapist, audiologist, social worker, or a registered nurse
• Must be capable of supervising multiple aspects of patient care and individuals providing that care
• Can be multiple individuals who are responsible for a group of patients or specific duties/responsibilities related to coordination of patient care
Still Have Questions? Download Tip Sheet — FAQs on Home Health’s New Role: The Clinical Manager
Frequently Asked Questions from the Webinar:
Question: Can one administrator oversee multiple agencies?
Answer: Yes, but…
• The administrator is expected to be available for all day-to-day operations and to receive complaints from patients, representatives and caregivers.
• The administrator’s active involvement in the agency’s operations must be demonstrated during surveys.
• CMS believes that “active involvement in daily operations and regular availability to patients, caregivers, representatives and would be difficult if not impossible” if the administrator is responsible for more than one agency on a given day.
Question: Can the clinical manager also be the director of nursing (DON)?
Answer: There’s nothing in the new CoPs language that specifically prohibits the DON from also being the clinical manager. BUT… the agency must be able to demonstrate that the person who will be the clinical manager is capable of fulfilling all of the responsibilities of the role. The larger the agency is, and the more new patients and care plans there are, the more difficult it will become for one individual to wear both hats.