New Conditions of Participation for Discharge Planning for Home Health Agencies

The Centers for Medicare and Medicaid Services (CMS) published a final rule on September 30, 2019, that requires home health agencies to make substantial changes in discharge planning. The final rule is effective sixty days from publication so it becomes effective on November 29, 2019.

We will present a teleconference on October 23, 2019, from 1:00 to 2:30 p.m. EST to review the changes to the Conditions of Participation (CoPs) in depth. Click here for more information. Please join us!

In the meanwhile, a significant changes in CoPs for home health agencies with regard to discharge planning is that agencies will be required to assist patients who are transferred to another home health agency or discharged to a SNF, IRF, or LTCH to select a post-acute provider.

Home health agencies must use and share data with patients and their caregivers that includes, but is not limited to, home health agency, skilled nursing facility (SNF), independent rehab facility (IRF), or long-term care acute hospital (LTCH) quality measures and data on resource use measures. The data shared with patients and their caregivers must be relevant and applicable to patients’ goals of care and treatment preferences.

The basis for this requirement is that CMS believes that recognizing patient preferences and assisting patients with transfer options will support communication between patients and home health agencies and ultimately support patient-informed decision-making and improve patient care and satisfaction.

CMS goes on to say information provided to patients and their caregivers must include data from IRF Compare, Home Health Compare, Nursing Home Compare and Long-Term Care Compare to assist patients and their caregivers to make decisions about post-acute providers.

CMS says home health staff members are not expected to provide patients and their caregivers with detailed and complex analyses of quality and resource use data that may confuse patients and their caregivers.

Home health agencies are also not expected to attempt to provide patients with data that does not exist. In other words, no “homemade data!”

According to CMS, home health agency staff members must put forth their “best effort” to answer patients’ questions about data presented to them. CMS says that home health agencies should also refer to www.medicare.gov
for additional resources and help with regard to data presented to patients and their caregivers.

Further information mandated by the IMPACT Act will be available in forthcoming regulations. CMS will also provide interpretive guidelines at some point after publication of the final rule. More to come in future articles on this topic!

©2019 Elizabeth E. Hogue, Esq. All rights reserved.

Southern Web SupportNew Conditions of Participation for Discharge Planning for Home Health Agencies
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