CMS Proposes Change to Home Health Agencies CoP
- On Thursday, October 9, 2014, the Centers for Medicare & Medicaid Services (CMS) announced a proposed rule that would revise the current conditions of participation (CoPs) that home health agencies (HHAs) are required to meet in order to participate in Medicare and Medicaid programs.
The rule contains a number of changes that focus on the quality of care that is delivered by home health agencies. They reflect an interdisciplinary view of patient care which would allow HHAs better flexibility in meeting quality standards and eliminate unnecessary procedural requirements.
“These changes are an integral part of our overall effort to achieve broad-based, measurable improvements in the quality of care furnished through the Medicare and Medicaid programs, while at the same time eliminating unnecessary procedural burdens on providers,” the report states.
The rules encompass the fundamental requirements for HHS services including patient rights, comprehensive patient assessment, and patient care planning and coordination by an interdisciplinary team.There would also be a quality assessment and performance improvement (QAPI) program that would build on the philosophy that a provider’s own quality management system is key to improved patient care performance.
Specifically, under the proposal, the HHA CoPs would still be designated under 42 CFR part 484. However, many of the current requirements in part 484 would be consolidated, revised or eliminated and require extensive changes in the current organizational scheme. This would include grouping together all CoPs that directly relate to patient care and place them at the beginning of part 484.
The restructuring will better keep patient-centered orientation of regulations and reinforce the CMS view that patient assessment, care planning and quality assessment and performance improvement efforts are critical pieces to delivering high quality of care.
Why this change is needed
The Federal Government is the largest payer of health care services in the United States and assumes a critical responsibility for the delivery and quality of care administered under its programs. Traditionally, this approach is handled through identifying health care providers that furnish poor quality care or fail to meet minimum federal standards. However, this approach comes with limitations.
Focusing on enforcement of prescriptive health and safety standards, rather than improving quality for all patients, has resulted in expending resources dealing with marginal providers. Instead, the focus should be on stimulating broad-based improvements in the quality of care delivered to all patients.
“This proposed rule would adopt a new approach that focuses on the care delivered to patients by home health agencies while allowing HHAs greater flexibility and eliminating unnecessary procedural requirements,” the report reads. “As a result, we are proposing to revise the HHA requirements to focus on a patient-centered, data-driven, outcome-oriented process that promotes high quality patient care at all times for all patients.”
Estimated burden
The report also features analysis of the burden hours and associated costs related to the implementation of the proposed rule. According to the research, the total burden in hours would be 3,797,595. Total cost in the first year would be $148,251,348 and $141,821,526 in the second year.
