NAHC: Delay or Rescind New Conditions of Participation Rule

Home health agencies need more time to comply with a recent comprehensive overhaul of the Medicare and Medicaid Conditions of Participation (CoP)—and the Centers for Medicare & Medicaid Services (CMS) should consider rescinding the rule entirely, a prominent home health industry association told senior CMS officials in a Feb. 2 letter.

The final CoP rule was published on Jan. 13, 2017, becoming the first major CoP revision since the late 1980s. The National Association for Home Care & Hospice (NAHC) now has officially requested that the effective date for the new rules be pushed back from July 13, 2017, to July 1, 2018, at the earliest.

The additional time is needed because of the “depth and breadth” of the changes and their estimated $300 million implementation price tag, NAHC argued in its letter. Agencies also still are awaiting crucial interpretive guidance from CMS, which has yet to be issued and is “not expected soon,” the letter stated.


NAHC also cited a recent poll it conducted of the home health community, which showed 57% of respondents said more time is needed for compliance. More than 28% said that the rule should be entirely rescinded and reconsidered.

Further supporting NAHC’s case, the Trump administration recently issued directives to slash regulations and put a hold on those that have not yet taken effect, the letter pointed out.

“The current performance of home health agencies uniformly shows high quality patient outcomes, virtually 100% compliance with the conditions of participation, and outstanding patient satisfaction,” NAHC Vice President for Law William Dombi wrote. “While the new rules may help continue those results, there is no quality of care problem in home health services that needs immediate actions to resolve.”


Written by Tim Mullaney

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