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New Medicare Conditions of Participation for Home Health in Effect: Questions and Answers

HH Medicare Conditions of Participation Questions and Answers

Axxess is committed to the industry’s success and continues to work relentlessly to ensure we provide the tools agencies need to successfully manage care in the home.

With the new Medicare Conditions of Participation (CoPs) for home health now in effect, Axxess has been providing webinars, blog posts, on-demand videos and other materials to ensure agencies are as prepared as possible to meet the new CoP requirements. Thousands have participated on webinars Axxess has hosted for the industry to hear from our expert clinicians, and we will be hosting more webinars over the next few days and in the coming weeks.

During these webinars, our team has responded to myriad questions about remaining compliant with the new CoP standards. We will share some of this information over the next few weeks to enable you to see what others are asking.

I understand the new CoPs change the agency Plan of Care responsibilities. How so?

One of the biggest changes is that under the new CoPs a patient is entitled to receive all of the services listed under the Plan of Care. This is something agencies need to keep an eye on because in the past many would document a vague statement about what care is to be provided. It is important that agencies be as specific as possible because the patient will be entitled to receive any care documented unless they refuse it.

Does the Plan of Care replace the old 485?

Yes, the new Plan of Care is replacing the 485 because there are areas on the plan of care with no locator on an old 485, such as the psychosocial assessment or the risk of rehospitalization assessment. However, we have made the new plan of care closely resemble the old 485 to ensure familiarity when sent to the physician or other providers.

I understand that for every change in a Plan of Care we need to provide the caregiver/ patient or patient’s representative a copy of the updated POC each time. Does CMS have any preference on how the update is provided?

CMS has given agencies the ability to choose how to deliver written information to the patient and patient’s representatives. As a matter of fact, in the questions and answers in the Final CoP rule, CMS verified that leaving a Plan of Care is not necessary. They did go on to say that the patient and representatives must be notified, so this will need to be documented, but the only standard as to what must be written in the home is in the section of the CoPs called “Written Information to the Patient”. As far as how this is delivered, CMS did say that written information must be hard copy, unless the patient or representative specifically asks for a copy electronically.

How often is the Plan of Care summary sent to the physician?

We are awaiting the final Interpretive Guidelines from CMS, as we have the same questions. However, our understanding at this time is that the Plan of Care should be sent no less than every 60 days, as is currently the rule. In addition, the Revised Plan of Care must be sent when the revisions are due to a significant change in condition due to the patient declining or improving unexpectedly. In a significant change scenario, a Follow-up OASIS Assessment would be completed, and the assessment will generate a new Plan of Care that can be sent for signature.

After the original Plan of Care is created, when we write an order for changes do we need to send this to a physician each time for compliance, or does the order we generate cover that?

Please check your agency policies, as well as accrediting body’s regulations for information on how often you are to send the Plan of Care. CMS has said that the plan of care should be sent no less than every 60 days for signature, unless a significant change in condition occurs and a new Plan of Care is completed. Since verbal orders are sent for signature, there is no need to send the Plan of Care for signature as well. The Plan of Care will be updated, and the verbal or supplemental order will be signed to verify this change. However, CMS does require that the physicians are notified of changes to the Plan of Care. So be sure to document how this information was communicated to these physicians, as well as to the patients and caregivers/representatives.

These are just some of the questions we have been receiving related to the new Medicare Conditions of Participation. For more information regarding the implementation of the CoPs, go to Axxess’ complimentary on-demand training videos or our library of CoP blog content.

If you have other questions, please visit our help center or email us at support@axxess.com.

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