Top 3 CoP Changes to Impact Home Health Agencies

The newly finalized home health conditions of participation (CoPs) will have wide implications for agencies, but not all the changes are new or likely to be costly.

The CoPs, which were updated after nearly three decades in a final rule issued in early January, aim to improve the quality of health care services for home health patients and strengthen patient rights, according to the Centers for Medicare & Medicaid Services (CMS).

The changes are coming with a high cost—up to $234 million in annual costs, according to CMS, with a short timeline for almost all the new regulations, which will go into effect July 13, 2017. That comes out to about $30,000 per agency, according to the National Association for Home Care & Hospice (NAHC), which recently held a webinar to discuss the impact of the new provisions.


At the same time, there is a question as to whether the new CoPs will go into effect at all on the designated timeline, following President Donald Trump’s recent orders to freeze all new regulations.

However, not all agencies will likely see such a high cost or even much impact if they go into effect on time, depending on what systems and staff they already have in place. For others, a few of the new conditions could require hiring new personnel and adding new technology.

Here are some of the CoPs that are likely to affect home health agencies the most, according to association groups:


1. Patient rights

One of the biggest changes to the CoPs is the addition of a patient bill of rights that must be clear and accessible to patients and staff. While not a new concept, the changes include more assessment components, encompassing psychological, functional and cognitive states of patients.

“This is the greatest change, with the greatest amount of work for individuals,” Bill Dombi, vice president of law at NAHC, said of the patient rights conditions during the web event.

Agencies will have to collect patient preferences and demonstrate progress toward patients’ identified goals—a new requirement. Home health providers must also identify family caregivers and their willingness and ability to help provide care.

2. Training and organization requirements

The CoPs include several mandates to facilitate communication and care coordination between providers, and a requirement that agencies have a clinical manager to do much of this work. Many home health agencies likely already have this position, or something similar.

“I see this as a hybrid between a clinical and case manager,” said Mary Carr, during the NAHC webinar. “A lot of patient care oversight is what this individual will be responsible for. You clinical managers may or may not already do [this]. It will probably be an additional personnel to come in, if not more [than one], to oversee all this care coordination.”

3. Quality assessment and performance improvement (QAPI)

The QAPI provision requires agencies to show more data collection and performance projects with opportunities to demonstrate improvement.  Some home health agencies may already be required to do this, while others may have a QAPI program in place. Agencies have many options to choose areas where they can attempt to improve care quality and performance.

This is also the only CoP that has a later implementation date—it will go into effect in 2018 for agencies that don’t have a QAPI program in place already.

The final rule, which is more than 300 pages in total, has raised some unanswered questions, and home health groups and agencies are still waiting on some more specific guidelines. The changes may require some new hires or organizational changes, but many of the provisions merely enhance concepts already in motion.

“The first step, take a deep breath,” Dombi told home health providers listening in.

Written by Amy Baxter

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