It’s a wrap! Last week, we aired our fifth and final webinar in the Conditions of Participation (CoPs) series. All five webinars in the series are now available on-demand, 24/7 at kinnser.com/cops. You can watch at your own pace, share with colleagues, and re-watch as often as you like.
While the series has ended, there’s still plenty left to learn before the January 13, 2018 effective date. We’ve compiled this list of related resources to help you prepare.
- FAQs on Home Health’s New Role: The Clinical Manager
- Bag Technique Article by Mary McGoldrick MS, RN, CRNI
- QAPI Self-Assessment Tool adapted from CMS
Review Past Recaps:
Stay tuned! We are producing even more educational content related to the CoPs — including a guide to CoPs requirements for home health aides and a compliance checklist comparing old vs. new CoPs requirements. New content will be available in the coming weeks!
Highlights from Webinar 5:
In Webinar 5, presenters Sharon Harder and Jill Dyer, BSN, RN, HCS-D, HCS-O shared valuable checklists for nursing, therapy, and medical social services, and also outlined new staffing requirements outlined in the CoPs — including new administrator requirements and home health’s new role, the clinical manager. Our presenters also discussed comprehensive new requirements regarding home health aide qualifications, training, supervision, and evaluations. Below are some of the highlights from their important presentation.
Nursing Requirements Checklist – §409.44
- Skilled services are those that must, under state law, be performed by a licensed RN or LPN/LVN.
- Skilled need is based on the patient’s condition and service complexity.
- Skilled need is not negated by teaching a procedure to the patient or his/her caregiver.
- If the service can be performed by the average, non-medical person, the absence of such a person to perform the service does not in and of itself make the service skilled.
- Skilled nursing services must be reasonable, necessary and based solely on the patient’s unique condition and need.
Therapy Requirements Checklist – §409.44
- Therapy services must relate directly and specifically to a treatment regimen (established by the physician, after any needed consultation with the qualified therapist) that is designed to treat the beneficiary’s illness or injury.
- Services related to activities for the general physical welfare of beneficiaries do not constitute physical therapy.
- Therapy services must be of a level of complexity and sophistication, or the condition of the beneficiary must be such that the services required can safely and effectively be performed only by a qualified therapist.
- The plan of care must describe the course of treatment and goals and the goals must be measurable.
- There must be an expectation of material improvement in function or documentation of why the services are required to maintain function and prevent further decline.
Medical Social Services Checklist – §409.45
- Medical social services must be ordered by the physician and included in the plan of care.
- The services must be necessary to resolve social or emotional problems that would impede the patient’s effective treatment or recovery.
- The services provided must be reasonable and necessary.
- The services must require the skills of a qualified social worker or assistant (as allowed by state law).
The Administrator — New Requirements
- An administrator hired on or after January 13, 2018 must be a person who:
- Is a licensed physician, a registered nurse, or holds an undergraduate degree; and
- Has experience in health service administration, with at least 1 year of supervisory or administrative experience in home health care or a related health care program.
- Current administrators are grandfathered relative to the qualification requirements.
- The interpretive guidance confirms CMS’s position that an undergraduate degree means a Bachelor’s or Associate’s Degree.
The Clinical Manager — New Requirement
The clinical manager is required to be:
- A licensed physician
- A physical therapist
- A speech language pathologist
- An occupational therapist
- An audiologist
- A social worker
- A registered nurse.