The updated Conditions of Participation (CoPs) taking effect January 13, 2018 will impact many areas of home health care, including personnel qualifications. These changes are outlined in Condition 484.115. This condition outlines qualifications for all disciplines except for aides, which is located in the aide services condition. There are big changes to administrators and a new one for clinical managers. Otherwise, there are relatively few additional minor changes in personnel. We will review the changes so you can be sure when it comes time to make your next hires in 2018, he/she meets the personnel qualifications.
If you are planning to hire a new administrator in 2018 the standard will include more stringent qualifications. This person must now have an undergraduate degree if he/she is not a RN or physician. Fortunately, a current administrator without an undergraduate degree is grandfathered in for their current home health agency (HHA) position.
However, an administrator who was previously employed as an administrator at a HHA prior to the January 13, 2018 implementation of the new CoPs will need to meet these NEW qualifications in order to work for a different HHA. Even an administrator with any number of years in home health agencies will now have to obtain a degree in order to be an administrator at a different agency.
For individuals who began employment as an administrator with a HHA prior to January 13, 2018, the person must be:
- A licensed physician;
- A registered nurse;
- Have training and experience in health service administration and at least one year of supervisory administrative experience in home health care or a related health care program.
For individuals that begin employment with a HHA on or after January 13, 2018, the person must be:
- A licensed physician, a registered nurse, or hold an undergraduate degree; AND
- Have experience in health service administration, with at least one year of supervisory or administrative experience in home health care or a related health care program.
The clinical manager position has been basically updated from what CMS has called the supervising nurse. The wonderful addition that was added, due to numerous comments calling for it in the proposed rule, is that a clinical manager can be a physical therapist, speech-language pathologist, occupational therapist, audiologist, or social worker, and as now, a registered nurse or a licensed physician.
An agency can also have one or several clinical managers. CMS felt that numerous deficiencies in home health required this addition. However, most agencies have always had a Director of Clinical Services and several nursing supervisors as well as a rehab manager, depending upon the size of the agency. So, the main change an agency would make is on the organizational chart. The director position could also be titled clinical manager (i.e. DCS/clinical manager) and the supervisors would be titled clinical managers.
Impact on Other Positions
The only revision for social worker and speech language pathology was the addition of a doctorate degree for qualifications. There were no changes for therapists or LPNs.
Personnel qualifications are just a sub-set of the many changes being implemented next year with the new CoPs. We can help ensure your staff is ready before January. For further information on the many training options we offer, please feel free to contact us at [email protected] or 866-428-4040.