Now is the Time to Prepare for the New Conditions of Participation

As I am sure you are aware, the new Conditions of Participation (CoPs) were published in January of this year and recently its effective date has been revised to January 13, 2018.  Even though the implementation date has been delayed, now is the time to start educating your staff and adding processes as necessary to ensure you are in compliance.

Getting to Know the New CoPs  

The updated CoPs were published in the Federal Register.  Looking at the document initially, you can become overwhelmed.  You may think this is such a comprehensive, document, but in reality, the new CoPs do not start until page 75 of the 88-page publication.  Prior to this page there are a summary, and background information, followed by comments on the CoPs proposed rules with responses.  These are very informative as they specify and clarify the intent of the CoPs.  Note that there are no interpretive guidelines presently in place, and there may not be any until July or later.  This is just one of the reasons why it is critical that all staff, including Administrators, Directors of Clinical Services, managers, supervisors, QAPI personnel are educated on the new CoPs starting now.

Patient Focused, Data Driven, Outcome Oriented

The goal of the new CoPs is to promote high quality patient care at all times for all patients.  Continuous care process across all services, based on patient centered assessment, care planning, service delivery and quality assessment / performance improvement are covered.  They take an interdisciplinary approach that recognizes the skills of the entire team.  Think case management ! They are very outcome oriented, making quality improvements through QAPI specific to each home health agency (HHA).  They are eliminating administrative processes that are not predictive of achieving clinically relevant outcomes for patients or preventing harmful outcomes, including PAC, annual evaluations and bylaws.  The goal of CoPs is to safeguard patient rights and have patients directly involved in all aspects of their care – patient driven!

There are 16 conditions in the new CoPs.  There are many changes to the patient rights condition.

  • Care planning, coordination of services and quality of care is a combined position and encompasses a lot of very critical new information for plan of care, updates to plan of care, coordination of service, etc.
  • New conditions are infection prevention and control, and QAPI.
  • Emergency planning, although not stated as new, has expanded greatly and is following the new rule for healthcare regarding emergency planning from 2016.


The new CoPs have many requirements.  Below are some of the overarching areas and their requirements.

  • Patients and caregivers must have written information about:
    • Upcoming visits,
    • Medication instructions,
    • Treatments administered,
    • Care instructions that the patient and caregivers perform,
    • Name and contact information of the home health agency clinical manager.
  • Integrated communication system implemented that ensures that patient needs are:
    • Identified and addressed,
    • Care is coordinated among all disciplines,
    • Active communication exists between the home health agency and the patient’s physician(s).
  • Data-driven, agency-wide quality assessment and performance improvement (QAPI) program that continually evaluates and improves agency care for all patients at all times:
    • Final Rule is going to be phased in over twelve months to allow HHAs the time necessary to collect data prior to implementing performance improvement projects. However, do not think this is a pass to wait until January 2018 to start QAPI.  You must have your plan and indicators in place and begin to monitor and trend analyze data, and implement action plans for improvement now.
  • Implement a new infection prevention and control program to:
    • Use of standard infection control practices,
    • Patient/caregiver education and teaching.
  • Have integrated skilled professional services that focuses on patient care activities and supervision across all disciplines.
  • Expand patient care coordination that makes a licensed clinician responsible for all patient care services to assure that care meets each patient’s needs at all times.
  • Increase qualifications for home health agency administrators and clinical managers.

We Can Help Prepare Your Team

Even this high-level overview of CoPs may seem overwhelming.  It is a big task to be prepared.  Along with this big task, comes a big price tag.  Each agency will spend on average $30,000 to implement the new CoPs.

We can help you with this preparation process.  Recently, I presented a four-part webinar series on CoPs.  Individual DVDs for each recorded webinar are available to purchase under the Training section on our website.  They will detail every condition and standard in the new CoPs related to home health.  However, if you are looking for a high-level overview instead, in the near future we will also offer a pre-recorded 90-minute session available on DVD that you can view at your convenience.  If you have questions about either education option, please contact us at  [email protected] or 314-952-8392.

Southern Web SupportNow is the Time to Prepare for the New Conditions of Participation
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