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New Medicare Conditions of Participation: Five More Questions and Answers

With the new Medicare Conditions of Participation (CoPs) 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.

During these webinars, our team has responded to a host of questions about remaining compliant with the new CoP standards. We have been sharing some of the questions we are getting and wanted to share a few more.

Do we have to perform a Follow-Up comprehensive assessment or SCIC (Significant Change In Condition) assessment if there is a significant change in the patient’s status?

Yes, CMS re-introduced this concept in the new Medicare CoPs. When the patient has an unexpected major improvement or major decline that would necessitate a change in the plan of treatment, a comprehensive assessment is required. In the updated AgencyCore system, this Follow-Up comprehensive assessment will generate a new plan of care. This plan of care should be sent for signature to the physician who is providing care plan oversight. All other physicians who are participating in giving orders toward the plan of care should be notified of changes and care should be coordinated with them as well.

When do we have to send a Transfer Summary and what must this summary contain?

When the patient has a planned transfer to a facility (e.g. hospital, long-term care facility) where care is to continue, the agency should send a transfer summary within two days to the receiving facility. This summary should contain all the following:

  • Admission and discharge dates
  • Physician responsible for the home health plan of care
  • Reason for admission to home health
  • Types of services provided and frequency of services
  • Laboratory data
  • Medications the patient is on at the time of transfer
  • Patient’s transfer condition
  • Patient outcomes in meeting the goals in the plan of care
  • Patient and family instructions

If the patient is transferred to a facility, and the agency is unaware until after the patient has been discharged from this facility, the agency does not have to send the transfer summary. However, if the patient is still receiving care in the receiving facility when the agency is made aware, the transfer summary must be sent to the facility within two days.

Can the home health agency bill the patient for providing clinical records on request?

No, the Conditions of Participation state that when the patient requests his or her clinical records, the agency must provide it free of charge by the next skilled visit or within four business days, whichever comes first. This can be delivered in electronic or hard copy form.

Can a non-licensed person serve as the clinical manager?

No, the clinical manager must be either a licensed physician, physical therapist, speech-language pathologist, occupational therapist, audiologist, social worker or a registered nurse. Some agencies are large enough to require more than one clinical manager to provide oversight of all patient care services and personnel. These oversight duties include making patient and personnel assignments, coordinating patient care, coordinating referrals, assuring that patient needs are continually assessed and ensuring the development, implementation, and updates of the individualized plan of care.

What information from the patient’s plan of care has to be left in the home in written form?

The following written information must be left in the home:

  • Visit schedule, including frequency of visits by agency personnel and personnel acting on behalf of the agency;
  • Patient medication schedule/instructions, including medication name, dosage, frequency and which medications will be administered by agency personnel and personnel acting on behalf of the agency;
  • Any treatments to be administered by agency personnel and personnel acting on behalf of the agency, including therapy services;
  • Any other pertinent information/instruction related to the patient’s care and treatments that the agency will provide, specific to the patient’s care needs; and
  • Name and contact information (business phone number) of the agency clinical manager. (The email may also be left, in addition to the business phone number, if the patient prefers electronic communication. Please be aware that all electronic communication must remain HIPAA compliant, however.)

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 Medicare 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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