Tuesday, January 21, 2020

Proposed Rulemaking on Conditions of Participation for Home Health Agencies: Revision of Requirements

Section 202 of the Unfunded Mandates Reform Act of also requires that agencies assess anticipated costs and benefits before issuing any rule whose mandates require spending in any 1 year of $100 million in 1995 dollars, updated annually for inflation. The estimates presented in this section of the final rule exceed this threshold and, as a result, we have provided a detailed assessment of the anticipated costs and benefits in RIA section as well as other parts of the preamble. Several of the requirements currently found at § 484.14, “Organization, services, and administration,” have been reorganized and revised under this condition. Phase three of the QAPI process builds upon the QAPI program that an HHA already has in place. We estimate that an HHA will use 3 hours a year to identify new domains and quality measures, and we believe that the QAPI committee will perform this task, at a total cost of $246 (1 hour × $63/hour for QAPI coordinator + 1 hour × $98/hour for administrator + 1 hour × $85/hour rate for clinical manager). The total annual cost for non-accredited HHAs in updating domain and measures is $1,876,980 ($246 per HHA × 7,630 HHAs) in year 2 and thereafter.

medicare conditions of participation for home health agencies

Each regional office, however, uses a different method of distributing survey funds to the states. BHI proceeded to draft Conditions of Participation that would be equivalent to those of JCAH. Except for utilization review, the 16 standards corresponded to the areas covered in JCAH's 1965 hospital accreditation standards. For example, they did not specify staffing ratios but referred to "adequate" staffing, "qualified" personnel, and an ''effective" staff organization. In a case management model, you will find that clinicians and aides have improved satisfaction as well; working with a team to care for patients allows them to be goal-oriented rather than simply making visits to change dressings or do exercises with the patient.

Medicare: A Strategy for Quality Assurance: VOLUME II Sources and Methods.

The data submitted under paragraph of this section must be submitted in the form and manner, and at a time, specified by CMS. CMS approves an HHCAHPS survey vendor if the applicant has been in business for a minimum of 3 years and has conducted surveys of individuals and samples for at least 2 years. For periods beginning on or after January 1, 2020, an HHA receives an outlier payment for a 30-day period whose estimated cost exceeds a threshold amount for each case-mix group. The outlier threshold for each case-mix group is the 30-day payment amount for that group, or the partial payment adjustment amount for the 30-day period, plus a fixed dollar loss amount that is the same for all case-mix groups.

The governing body would be required to define, implement, and maintain a program for quality improvement and patient safety that was ongoing and agency-wide. The governing body would be required not only to ensure that performance improvement efforts were prioritized, but that they were also evaluated for effectiveness. We note that it is the governing body which would be ultimately responsible for establishing the HHA's expectations for patient safety through an agency-wide QAPI program. Therefore, we proposed that the governing body establish clear expectations for patient safety. We also proposed that the governing body would appropriately address any findings of fraud or waste in order to assure that resources are appropriately used for patient care activities and that patients are receiving the right care to meet their needs. By and large, these capacity-oriented standards are based on professional consensus, although some are based on research.

PART 410—SUPPLEMENTARY MEDICAL INSURANCE (SMI) BENEFITS

However, the proposed rule states that an occupational therapy assistant is a person who “fter January 1, 2010, meets the requirements in paragraph of this section.” There is no paragraph in the proposed rule text. While some commenters suggested that the role be eliminated altogether, other commenters sought clarification regarding its function, goals, and operational implementation. A commenter asked if this role was intended to be filled by the individual who would provide hands-on care in the field, or if it could be filled by a supervisor who may not be out in the field. Another commenter expressed a similar concern, asking whether the clinical manager would be responsible for oversight of certain agency functions or whether the clinical manager would have to perform the functions himself.

Contact information for the HHA administrator, including the administrator's name, business address, and business phone number in order to receive complaints. Avoidance of future adverse events, more appropriate resource allocation, and a wide variety of other beneficial outcomes, based on the projects selected by each HHA. Educate HHA employees and contractors on the new domains and measures, as well as the policies and procedures for them. Recommendations to minimize the information collection burden on the affected public, including automated collection techniques. The table below shows the relationship between the former sections to the new regulations. This section explains why notice-and-comment is impracticable, unnecessary, or contrary to the public interest.

Medicare and Medicaid Programs; Hospital Conditions of …

Performance improvement activities must track adverse patient events, analyze their causes, and implement preventive actions. The frequency and detail of the data collection must be approved by the HHA's governing body. Be advised of the state toll free home health telephone hot line, its contact information, its hours of operation, and that its purpose is to receive complaints or questions about local HHAs.

Also, the proportion of noncompliance with each condition is similar for accredited and unaccredited hospitals (Table 7.5). Together with Medicare Part B, it makes up what is known as Original Medicare, the federally administered health-care program. Medicare Part A helps pay for the cost of inpatient hospital care, while Part B covers outpatient medical services. For example, the physical therapy assistant notes that the patient has more ankle edema and is more fatigued. The PTA knows that the patient has a comorbidity of CHF, reports this to the team in the EMR, and also specifically notifies the nurse and physical therapist.

The commenter stated that in many cases, it is uncertain who at a hospital should receive the information. Additionally, the commenter stated that, generally, the discharge or transfer information would not be used in the diagnosis or treatment of the hospitalized individual. Another commenter requested that if the HHA is not able to meet the timeframe requirements, CMS should permit the HHA to document the reason in the medical record.

medicare conditions of participation for home health agencies

Continues to allow home health agencies to have branch offices, but eliminates “subunits.” Designating an HHA location as a “subunit” is a vestige of the old HHA payment system. Under the current payment system, having HHA “subunits” is no longer necessary. This change allows parent agencies to have greater control over all of their offices by placing all locations under the leadership and direct management control of the parent agency. The process for requesting the addition of a branch office would remain unchanged.

At § 484.65, “Program Activities,” we would require an HHA's QAPI program activities to focus on high risk, high volume, or problem-prone areas of service, and to consider the incidence, prevalence, and severity of problems in those areas. We also proposed that the HHA immediately correct any identified problems that directly or potentially threaten the health and safety of patients. Additionally, the HHA's QAPI activities would have to track incidents and adverse patient events, as well as analyze those events, so that preventive actions and mechanisms could be implemented by the HHA.

medicare conditions of participation for home health agencies

JCAH carried on the ACS principles for improving health care in hospitals—voluntary private accreditation, minimum health and safety standards based on the consensus of health professionals, and confidential on-site surveys that involved education and consultation as well as evaluation (Roberts et al., 1987). In 1961 JCAH began to hire its own surveyors rather than use ACS and AMA staff and in 1964 it began to charge a fee for inspections . By 1965, when the legislation creating Medicare and Medicaid was passed, JCAH was already accrediting 60 percent of the hospitals with 66 percent of the beds (1.13 million of 1.7 million) . The Joint Commission on Accreditation of Hospitals was created in 1951 to accredit hospitals that met its minimum health and safety standards.

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