Home Health Conditions of Participation Delayed Six Months

After proposing to push back the implementation date of the new home health care conditions of participation (CoPs)—the requirements for home health care agencies (HHAs) to participate in Medicare—the Centers for Medicare & Medicaid Services (CMS) finalized the rule on Friday, July 7.

The effective date for HHAs to comply with the new requirements is Jan. 13, 2018, six months later than the original July 13, 2017, date. The delay gives agencies more time to prepare for the changes, which represent the first significant update in decades.

The decision was largely expected, after CMS proposed pushing back the effective date in March. Industry groups applauded the announcement Friday.


“We are very pleased that CMS extended the new CoP compliance deadline,” Bill Dombi, vice president for law at the National Association for Home Care and Hospice (NAHC), told Home Health Care News. “Home health agencies needed more time to make the necessary changes. However, we do believe that CMS should accelerate the issuance of interpretive guidelines so that agencies can make all the right changes.”

CMS stated in the final rule issued Friday that the final version of the Interpretive Guidelines will be published in December 2017. However, industry groups are urging the federal agency to publish the guidelines as soon as possible. CMS stated that a delay in the guidelines would not require further delay of the effective date for the CoPs.

“We still feel that it is vital that the interpretive guidelines be released as soon as possible and appreciate the timing update that was included in the delay’s final rule,” Joy Cameron, vice president of policy and innovation at ElevatingHome, told HHCN. “However, we would stress that in order for there to be clarity between CMS’ expectations for home health agencies and what surveyors will assess, the guidance and education are vital for this to be a smooth transition.”


The CoPs include several major changes for home health care agencies, including Quality Assurance Performance Improvement (QAPI). Performance improvement projects will be phased in slower than other QAPI requirements, with a phase-in date of July 13, 2018.

“These changes are an integral part of our overall effort to achieve broad-based, measurable improvements in the quality of care furnished though the Medicare and Medicaid programs, while at the same time eliminating unnecessary procedural burdens on providers,” the rule reads.

There are some lingering concerns by NAHC in the latest rule on some of the impending changes, including the requirement to convert subunits to independent or parent HHAs.

NAHC is hoping that CMS will issue further guidance on the transitions of subunits to branches or parent home health agencies.

“Subunits are eliminated in the new CoPs,” Dombi said. …”If subunits cannot transition to a new status on a timely basis, patients and the home health agencies will be hurt.”

Written by Amy Baxter

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