As of January 30, 2019 CMS has officially ended the moratorium for newly enrolling Home Health Agencies (“HHA”) that had been in place in Illinois, Michigan, Texas, and Florida since August 2016.
Accordingly, providers in these states who have been unable to reach a significant patient population now have the ability to do so. An estimated 82.5% of persons using Home Health services are eligible for Medicare. Prior to enrolling in Medicare, however, it is important to ensure your facility meets the requirements to enroll.
The removal of the moratorium is coupled with the new HHA Conditions of Participation (“CoPs”), which went into effect last year. According to CMS, the requirements focus on the care delivered to patients, allow HHAs greater flexibility in meeting quality care standards, and eliminate unnecessary procedural requirements.
Important Select Changes to the HHA CoPs from 2018 include:
- Patient Rights – The new patient rights CoP is divided into six separate standards. New standards include Transfer and Discharge, Investigation of Complaints, and Accessibility.
- Comprehensive Assessment of Patients – To establish a more complete understanding of the patient’s condition, strengths and limitations, preferences, and risk factors, additional content is required as part of the patient’s comprehensive assessment.
- Quality Assessment and Performance Improvement (“QAPI”) – The new rules replace 42 CFR § 484.16 (Group of professional personnel) and 42 CFR § 484.52 (Evaluation of the agency’s program) with a single new CoP for QAPI. The new CoP includes five standards: program scope, program data, program activities, performance improvement projects, and executive responsibilities. Note that performance projects have a phased in compliance date of July 13, 2018 to allow six months for the collection of data.
- Clinical Records – Changes to clinical records include updated clinical record contents, authentication requirements, and retrieval of clinical records.
Note that this list is not exhaustive. Rather, it is intended to identify notable changes to the CoPs. There are a number of additional revisions made by CMS and it is important that your organization comply with all aspects of the new rule.
Advis has significant experience providing services to HHAs and with provider-enrollment services. Advis is available to work with providers to assess compliance with and implement required changes to meet the new standards prior to enrollment before the window closes. For more information on how will affect your organization, or for further assistance, give Advis a call at 708-478-7030.
