The new CoPs (Conditions of Participation) include many revisions and/or additions. Various home health positions, including skilled professionals, are being impacted by them. In a previous blog we discussed the impact on home health aides, but in this blog we will review Condition 484.75, which covers skilled professional services.
The new CoPs combines the individual Conditions for skilled nursing, therapy and medical social workers into one, emphasizing the integrated team approach. Skilled professionals who provide services to HHA (home health agency) patients directly or under arrangement must participate in the coordination of care and participate in the HHA’s QAPI program and any in-service training.
The three standards that are covered in this single Condition are:
◦ Provision of Services by Skilled Professionals
◦ Responsibilities of Skilled Professionals
◦ Supervision of Skilled Professional Assistants
Provision of Services by Skilled Professionals
Per this standard, skilled professional services are authorized, delivered and supervised only by health care professionals who meet the appropriate qualifications and who practice according to the HHA’s policies and procedures.
Responsibilities of Skilled Professionals
COMMENT: Expectations for all skilled professionals rather than specific tasks for each discipline.
RESPSONSE: “…best interest of the HHA staff that each discipline be held to the same hgh standard, and combining all discipline-specific requirements into a single standard will help assure that all disciplines are being equally held to the same expectations. …applying the same expectations to all disciplines will facilitate HHA compliance with the regulations as well as facilitate survey consistency”.
Skilled professionals must assume responsibility for, but are not restricted to, the following:
- Ongoing interdisciplinary assessment of the patient.
- Development and evaluation of the plan of care in partnership with the patient, representative (if any), and caregiver(s).
- Providing services that are ordered by the physician as indicated in the plan of care.
- Patient, caregiver, and family counseling.
- Preparing clinical notes.
- Communication with all physicians involved in the plan of care and other health care practitioners (as appropriate) related to the current plan of care.
- Participation in the HHA’s QAPI program.
- Participation in HHA-sponsored in-service training.
Supervision of Skilled Professional Assistants
- Nursing services are provided under the supervision of a registered nurse that meets the requirements of § 484.115(k).
- Rehabilitative therapy services are provided under the supervision of an occupational therapist or physical therapist that meets the requirements of § 484.115(f) or (h), respectively.
- Medical social services are provided under the supervision of a social worker that meets the requirements of § 484.115(m).
Training is Key
The skilled professional services Condition is new and it is critical that your team is up-to-date on it as well as other revised and new Conditions of Participation. Since CoPs have not been revised in decades it is key to provide the proper training for your staff. We at 5 Star Consultants offer training on CoPs as well as many other home health and hospice topics. For further information about our many training programs, please feel free to contact us at [email protected] or 866-428-4040.