The revised CoPs (Conditions of Participation) are affecting many areas of the home health industry, including the comprehensive assessment of patients. Each patient must receive, and every home health agency (HHA) must provide a patient specific comprehensive assessment. For Medicare beneficiaries, the HHA must verify the patient’s eligibility for the Medicare home health benefit including homebound status, both at the time of the initial assessment visit and at the time of the comprehensive assessment.
Impact of Standards
- Initial Assessment of Patients
The initial assessment occurs at the first visit.
- Completion of the Comprehensive Assessment
For this standard, the same requirements are in force: nursing is on multidisciplinary cases (nursing and therapy), the RN must do the assessment.
- Contents of the Comprehensive Assessment
The comprehensive assessment must accurately reflect the patient’s status, and assess or identify the following:
- The patient’s current health as previously. However, a patient’s psychosocial functional and cognitive status are also covered, which is new per the recently introduced CoPs.
- Final Rule RESPONSE – “Assessing a patient’s psychosocial status refers to an evaluation of mental health, social status, and functional capacity within the community by looking at issues surrounding both a patient’s psychological and social condition.
- We are not requiring the use of any particular tool, nor are we prescribing the extent of the cognitive status assessment.
- Our goal is to make cognitive assessment a routine practice in HHAs so that HHAs can use this information in developing and implementing the patient specific POC.
- HHAs identify potentially unmet patient needs that warrant follow-up care with another health care provider, with the HHA making appropriate referrals as needed.
- We agree that there is crossover between these assessment elements and those items already included in the OASIS. However, those items included in the OASIS may not be sufficient for all patients. That is to say, some patients may require additional assessment beyond what is required in the OASIS.”
Most agency assessments already do comply with the additions of patient’s psychosocial, functional and cognitive status.
- The patient’s strengths, goals, and care preferences, including the patient’s progress toward achievement of the goals identified by the patient and the measurable outcomes identified by the HHA are new.
- Final Rule RESPONSE – “Traditionally the HH POC has been developed with a focus on patient deficits that require treatment ….
- This model of care places patients in a passive recipient role that does not optimize the achievement of positive patient outcomes.
- This model does not take into account patient strengths that can be harnessed by the HHA staff and POC to facilitate patient well-being.…
- Each patient has their own set of care preferences, and we require HHAs to identify and respect these care preferences to the greatest degree possible.
- Our goal is to assure that HHAs plan for and provide care that is both patient-directed and in accordance with the physician ordered plan of care.”
Be sure to document all a patient’s strengths, goals, and care preferences and progress towards goals! And although care preferences are important, be sure you are following physician orders at the same time!
Also, this standard includes the following:
- The patient’s continuing need for home care.
- The patient’s medical, nursing, rehabilitative, social, and discharge planning needs.
- A review of all medications the patient is currently using.
Be sure to give the patient their medication profiles, and update with each revision, as in the patient rights written information standard.
- The patient’s primary caregiver(s), if any, and other available supports (new), caregiver ability and willingness to assist.
Specifics are needed in order to ensure when a procedure, for example, is ordered, that a caregiver is present. Document this!
- The patient’s representative (if any) is new – patient’s legal or the NEW patient selected representative.
- Incorporation of the current version of the Outcome and Assessment Information Set (OASIS) items. . .
Update of the Comprehensive Assessment – Resumption of Care
Within 48 hours of the patient’s return to the home from a hospital admission of 24 hours or more for any reason other than diagnostic tests, or on physician-ordered resumption date is new to this standard.
This is a welcome change as the current CoPs do not allow for any ROC done after 48 hours. So now it is the same as for SOC OASIS, in which a physician ordered ROC date is compliant.
Ready for CoPs
The comprehensive assessment of patients includes many new standards that staff need to be knowledgeable about by the January 2018 CoPs deadline. Our experts at 5 Star are always up-to-date on policy and regulation changes in the industry. As we always say the only constant is change!
To keep up with the ever-changing healthcare industry, we offer training and webinars on this topic. To receive more information on training options, please feel free to contact us at [email protected] or 866-428-4040.