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Home Health Aide Recognized as Integral in Updated Conditions of Participation


The importance of the home health aide, as part of the patient care delivery team, is formally recognized in the updated Medicare Home Health Conditions of Participation (HH CoPs). For those of us who have worked on a team with an aide in the home health industry, we have long recognized this fact. CMS has now recognized the importance of aides and developed new requirements.

Home health aides performs important tasks, including:

  • Taking and recording vital signs;
  • Caring for the patient’s environment;
  • Recognizing changes in the patient’s body functions or cognition;
  • Reporting changes to the supervisor;
  • Bathing, grooming, dressing and assisting with toileting;
  • Assisting with turning, positioning, transfers and mobility;
  • Providing skin care;
  • Using assistive devices properly;
  • Reminding patient of medication and hydration; and
  • Assisting with safety precautions.

Due to the intimate nature of the aide’s duties, they often form a special, trusting relationship with patients. In my experience as an aide, many reminiscent stories and exchanges of laughter, among other things, have been known to occur during bath time. This rapport lends itself to patients sharing information with the aide that might not otherwise be shared with the clinical team. For example, aides have an ongoing opportunity to assess the patient’s skin for changes more readily than the other team members.

The newly updated HH CoPs recognize the significance of the home health aide’s role in the overall team of care delivery. Due to this shift, new requirements for aide training have been developed. According to 484.80(b)(3), aides must be trained in communication skills, including the ability to read, write and verbally report clinical information to patients, representatives, caregivers and other home health agency staff. They must also be trained on recognizing emergencies, and how and when to implement emergency procedures. Lastly, in 484.80(b), aides must be trained to recognize changes in patient skin condition. Aides are not to function as trained clinical professionals and stage pressure ulcers, but rather to be aware that changes in skin appearance are important to monitor and changes must be reported to supervisors.

The updated HH CoPs create a new interdisciplinary team requirement, which will impact aides’ job function. According to 484.80(g)(4), requirements state that home health aides must be members of the interdisciplinary team, report changes in the patient conditions to a registered nurse or other appropriate skilled professional, and complete appropriate records in compliance with specific home health agency policies and procedures.

Agencies are given flexibility on how aides function within the interdisciplinary team, and since this interdisciplinary team is a new standard, agencies must decide how they want to model this approach. Some may choose to model teams after the hospice interdisciplinary team model, for example each agency’s needs and populations served will need to be taken into consideration, and employees will need to be educated on new policies and procedures.

Home health agencies must ensure aides, whether full time, part-time or contracted staff, are trained on the new regulations prior to the implementation date of the new HH CoPs. Training may be done through routine in-service training, and agencies should maintain documentation that demonstrates meeting requirements. I recommend filing a copy of the in-service training and sign-in sheet in the agency’s in-services binder, as well as a copy in each aide’s personnel records. However, once the HH CoPs Interpretive Guidance Manual for Surveyors is published, we will know precisely what surveyors will be looking for when assessing compliance.

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