What Home Health Learned From the CoP Interpretive Guidelines Draft

Last week, the Centers for Medicare & Medicaid Services (CMS) released a draft of the much-anticipated interpretive guidelines for the Conditions of Participation (CoPs), finally giving home health care agencies some clarity on the new requirements.

The draft comes as the deadline for the implementation of the new CoPs is winding down; the effective date is currently scheduled for January 13, 2018.

Despite learning some new information from the draft, stakeholders are still waiting for more clarity on a number of the new CoP requirements, including:


—484.55(c)(5c): Medication management. The interpretive guidelines included more information on communication with physicians, but the industry “needs guidance on expectations for the nurse,” according to Joy Cameron, vice president of policy and innovation at ElevatingHome.

—484.60(d)(1): Communication with physicians in the care plan. When discussing coordination with all physicians, the interpretive guidelines missed coordination with advanced practice registered nurses (APRNs), according to Cameron.

—484.102: Emergency preparedness. As home health and other providers prepare for new emergency preparedness requirements, HHAs need more guidance, as the interpretive guidelines in the CoPs directly refer to “facilities.” However, most HHAs don’t have facilities, and need guidance specific to this care setting.


In addition, the communications guidance for emergency preparedness requires rural areas to have a back-up plan in the case of loss of cell coverage or internet. But the requirement should potentially extend to all providers, Cameron argues.

“As evidenced by recent natural disasters, should it just be a backup communications plan for everyone?” she said.

The draft interpretive guidelines also included some good information for providers as well.

“The draft IGs includes some welcome clarifications, such as: not requiring that the home health plan of care be submitted to the physician every time a verbal order is received, and that an associate degree is considered an undergraduate degree to satisfy the qualifications for the administrator,” Mary Carr, vice president for regulatory affairs for the National Association for Home Care & Hospice (NAHC), said in a letter to NAHC members.

CMS asked select groups directly for feedback on the draft of the interpretive guidelines, with comments due by November 15.

The agency has previously stated it will likely release the finalized interpretive guidelines in December, leaving a short timeline for agencies to fully prepare. Without a finalized version of the guidelines, some have speculated that another delay could be coming.

Written by Amy Baxter

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