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Medicare Conditions of Participation FAQs

Software Functionality

I am getting an error message.

If you are getting an error message when assessing the new features in the software please please clear your cache.

 

FIREFOX

1.Click on the orange fire fox icon on the top left corner 2.Go to Options from menu 3.Select privacy 4.Click on clear recent history

 

CHROME AND INTERNET EXPLORER

Control +F5 at the same time

 

MAC

Command +F5 or Command +Shift+R

 

IPAD   

Go to Settings. Choose "Safari" on left side menu. Click "Clear History" and "Clear Cookies and Data".

I can’t create or edit an order

If you need an order for a reason other than one listed, choose SUPPLY MANAGER, this will open a box where you will be able to type in your order.  The order will not be labeled SUPPLY.

My county will not populate in my OASIS

Remove the zip code and add it again, this will allow you to choose a county from the drop down.

Read back and verified in new orders

Please insure that you are checking the option for READ BACK IN VERIFIED when creating an order.  If the order is submitted without it will not be available once QA’d.

 

If the order was sent without checking the box please have them type in ORDER READ BACK AND VERIFIED.

What happen to ADD TEMPLATE

This feature is currently unavailable.

Why can’t I LOAD A PREVIOUS ASSESSMENT, PLAN OF CARE or ORDER

The currently set up requires a great deal more information and detail then pervious versions.  This information is disable for copying over information prior to January 13, you will be able to use the feature going forward with the new information.

What is a Clinical Manager

The standard for clinical manager, as per Subpart C, 484.105(c) describes the clinical manager as part of the "administrative and supervisory functions" of the home health agency. At 484.105(c), the Clinical Manager is: "one or more qualified individuals who must provide oversight of all patient care services and personnel. Oversight must include the following €” 1) making patient and personnel assignments 2) coordinating patient care 3) coordinating referrals 4) assuring that patient needs are continually assessed, and 5) assuring the development, implementation, and updates of the individualized plan of care."

 

The qualifications for the clinical manager are laid out in Subpart C, standard 484.115(c) "Standard: Clinical Manager. A person who is a licensed physician, physical therapist, speech-language pathologist, occupational therapist, audiologist, social worker, or a Registered Nurse."

 

Are there any mini mental exam at recert to get a better cognitive status assessment?

The mini mental exam is one of many cognitive assessments that can be used. Please check your agency's policies to see what you are required to use. Because each agency has its own requirements, AgencyCore does not have a mini mental exam built in. Your agency will have the functionality to upload any assessment you select in your policy and attach it to the OASIS task.

Can I write “Agency may accept orders from all physicians involved in patient care” or should names be entered into plan of care?

All physicians involved in the patient's home health plan of care should be listed on the care plan. Please check your agency policy for guidance on how your agency handles this. Remember that you must communicate all changes in the plan of care to all physicians who are involved in the patient's plan of care.

 

Will the software help create summary of care for patients?

AgencyCore will create a plan of care summary using updates to the plan of care from the supplemental/verbal physician orders created during the episode.

 

What about existing patients, do we need to do new start of care for our current patients? Or do we just give them the documents that are needed to be in compliance with the COPs?

For existing patients, you should supplement their information with updated list of patient rights, notifications, written information, and notification of changes in the plan of care/treatment/medications. This should be documented in the clinical record.

 

Does Axxess or CMS have any of the newly required forms needed for patients/representatives to sign within as required?

Because these forms will differ according to your state regulations, accrediting body regulations and agency policies, neither CMS nor Axxess are providing any specific notification forms.

 

Will Axxess accept 485 updates?

Yes, updates through supplemental/verbal/physician orders will flow into an evolving plan of care, with an accompanying plan of care summary. Please note that the 485 is now obsolete; however, our new compliant plan of care looks very similar to the old 485, so it will be familiar to you and physicians.

 

 Can the LPN do or write an order?

Each state's nurse practice act dictates what the LPN/LVN can and cannot do. Please refer to the Nurse Practice Act in your state, as well as your agency's policies, for this information.

 

Are all these new updates are for Medicare patients only or for HMO enrolled Medicare patients as well?

Any agency that participates in billing Medicare for home health services must comply with the CoP's. However, these conditions are to be applied to all patients served by the Medicare certified agency.

 

Can I add time to orders?

Yes, the clinician documenting a verbal order will have the ability to add the time the verbal order was received.

Do we need a D/C order? We usually do not write an order for DC because it hold up the final bill.

Please refer to your agency's policy regarding the need for a discharge order. In most agencies, the discharge order is only required if an unexpected discharge is required. If the patient is discharged at the end of a planned cert period frequency, a discharge is not required unless agency policy, accrediting body, or state laws state otherwise.

 

What if the lawyer who is a patient's representative is asking for the record, is 4 days applicable?

Please check with your legal consultant for this information. I would imagine that the 4 business days versus next visit standard still applies, although this scenario was not brought up in the draft interpretive guidance or final rule for the CoPs.

 

If the patient had not selected patient representative, can we document that in the comprehensive assessment and that suffice the COP standards?

Thank you Yes, if the patient has not selected a patient representative, this should be documented in the clinical record.

 

Am I correct in stating that any new orders/changes to POC require updates of POC only at time of resumption and significant change in condition?  Or should we update the POC anytime there is a new order?

According to CoP regulation, all verbal orders must be on the plan of care. In AgencyCore, when a supplemental or verbal order is recorded, it will update the plan of care for you.

Can the Director of Nurses be the Clinical Manager of the HHA? Yes, the DON can fulfill the role of the Clinical Manager as long as all the qualifications of Clinical Manager are met.

Is the clinical manager the same as the office case manager or the field staff case manager?

According the CoPs, the Clinical Manager is one or more qualified individuals must provide oversight of all patient care services and personnel. Oversight must include the following–

                   (1) Making patient and personnel assignments, (2) Coordinating patient care, (3) Coordinating referrals, (4) Assuring that patient needs are continually assessed, and (5) Assuring the development, implementation, and updates of the individualized plan of care.

Can the Director of Nurses be the Clinical Manager of the HHA?

Yes, the DON can fulfill the role of the Clinical Manager as long as all the qualifications of Clinical Manager are met.

Is DON position/title being eliminated due to the COPs?

No, the Director of Nursing is not being eliminated; the DON can function as a Clinical Manager as well, as long as all qualifications are met.

Does the 485 to be sent to the patient need a MD signature or can the POC be sent without the MD signature?

The patient is not required to have a 485 or plan of care. CMS stated that this plan of care contains jargon that may not benefit the patient. Therefore, a new standard "Written Information to the Patient" was created. This does not have to have a physician's signature before it is delivered to the patient.

Is a comprehensive assessment needed for a patient seen once or twice who refused further care or would a discharge summer be enough?

If the patient was admitted for care, and that care was expected to continue past the first or second visit you describe, you would need to write an order to discharge and complete a discharge OASIS assessment as well as a discharge summary.

Are there recorded copies of the Medicare CoPs webinars from this week?

Home Health Medicare Conditions of Participation Overview

Axxess Medicare CoP Features and Functionality

 

Do we still need to do a 60 Day Summary?

CMS no longer requires the 60 day summary. The ongoing coordination of care and notifications to the patient/caregivers/representatives and physician(s), as well as the requirements for Transfer and Discharge summaries will take the place of the 60 day summary

 

Do we need to do a 30 Day Summary?

CMS does not require 30 day summaries, but if your policy is to do them, or you have state or accrediting body standards that require this, you will continue to need to complete these

 

Does this F2F Addendum serve as the F2F?

The Face to Face Addendum serves as a supplement to the physician or provider’s face to face documentation. If the face to face encounter note you receive is incomplete, CMS and the MACs have said that the agency can submit additional documentation to the provider, who then must sign off and make this additional information part of his or her clinical records. Once this is done, the agency can use this additional information to supplement the face to face received by the physician. An example of this would be if the physician states in the F2F that patient is homebound due to taxing effort. We know that is not enough information for our MACs, so the clinician can add additional homebound status information and send to the physician to supplement.

Will the POC still have box 26 that will have to be filled in by physician?

Locator 26 is the certification/recertification statement on the old 485 plan of care. This statement is still available in the OASIS, and will flow over to the plan of care. It is also editable as it was before. Please be sure to check Publication 100-2, Chapter 7, Home Health Manual, for additional information on the certification and recertification statement requirements.

 

When the nurse is choosing interventions in the OASIS, will show up on the POC?  Will the problems show up in the Plan of care summary?

the problem statement you click on in the OASIS to select the interventions and goals will not show up on the Plan of Care. Only the interventions and goals.

I don’t think that all my orders need to be included in the Plan of Care

The updated Conditions of Participation states that all verbal orders must be reflected in the Plan of Care.

What is required to document a missed visit?

CMS requires that all changes to the Plan of Care are communicated to the physician.  Since a missed visit is a change to the Plan of Care, this must be communicated to the physician.  CMS requires documentation that this was done, but does not require a physician’s signature.  However, your accrediting body, state law or agency policy may be more stringent than CMS regulations.  Check your agency policy for required documentation for missed visits to ensure you are compliant, as the surveyor will go with the most stringent requirement, if there are different requirements.

Do the patients have to sign the Plan of Care?

CMS doesn’t require that the patient sign the Plan of Care.   The clinician should document in their narrative about the patient being involved in the formation of the Plan of Care and the treatment plan (or not).  The patient WOULD need to sign any applicable Advanced Beneficiary Notices (ABN) and/or Home Health Change of Care Notices (HHCCN).  These CMS forms can also be used to prove the coordination of care an notification/informed consent was obtained.  Be sure to consult your accrediting body’s regulations as well, they may be more stringent than CMS’s guidelines.