CoPs-Infection-Care-Planning

Breaking Down the New Home Health Conditions of Participation: Infection Control, Care Planning & Coordination

Update: On Friday, March 31, 2017, CMS issued a proposed rule to change the new Home Health Conditions of Participation effective date from July 13, 2017 to January 13, 2018. While this change in effective date is currently just a proposed rule, it is expected that the final rule will be consistent with the proposal. We will update our blog as more information becomes available. Despite the potential for delay, home health agencies should not cease or postpone preparation for the new CoPs.

To help you prepare for the new Conditions of Participation, HEALTHCAREfirst has partnered with home health care consultant and regulatory expert, Mary St. Pierre, RN, BSN, MGA, for a series of blog articles regarding the regulatory changes to the CoPs that will likely require amended policies, procedures, and forms.

In part one of our blog series on the Home Health Conditions of Participation (CoPs), we discussed the creation and implementation of a QAPI plan, policies, and procedures. In this article, Mary will break down §484.70 Condition of Participation: Infection Prevention and Control as well as §484.60 Condition of Participation: Care Planning, Coordination, and Quality of Care. Please note that this is only a summary of many of the CoP changes and you should refer to the revised Conditions of Participation for complete details.

Infection Prevention and Control
This addition to the CoPs is designed to encourage greater focus on infection prevention and control. It says that home health agencies must maintain and document an infection control program that has as its goal the prevention and control of infections and communicable diseases and is a component of the agency’s QAPI.

Standard: Prevention
This standard ensures that the infection control program follows accepted standards of practice to prevent the transmission of infections and communicable diseases.

Standard: Control
Home health agencies must maintain a coordinated agency-wide program that includes:

  • Surveillance
  • Identification
  • Prevention
  • Control
  • Investigation of infectious and communicable diseases

In addition, the infection control program must include:

  • A method for identifying infectious and communicable disease problems
  • A plan for the appropriate actions for improvement and disease

Standard: Education
The last standard in the Infection Prevention and Control CoP requires that the home health agency provides infection control education to staff, patients, and caregiver(s).

 

Care Planning, Coordination, and Quality of Care
This CoP requires that each patient have a written plan of care, including written revisions and/or additions. The plan of care must include (and patient receive):

  • Care and services necessary to meet the patient-specific needs
  • Responsible discipline(s)
  • Patient-specific measurable outcomes
  • Patient and caregiver education and training
  • Established, periodically reviewed, signed by a doctor of medicine, osteopathy, or podiatry
  • Policy: Must be reviewed and signed by the physician responsible for plan of care

There are also additions to what is already reported in the plan of care including:

  • A description of the patient’s risk for emergency department visits and hospital re-admission
  • Patient-specific interventions to address the underlying risk factors
  • Patient and caregiver education and training to facilitate timely discharge
  • Patient-specific interventions and education
  • Measurable outcomes and goals identified by the HHA and the patient
  • Information related to any advanced directives
  • Any additional items the HHA or physician may choose to include
  • All patient care orders, including verbal orders, must be recorded in the plan of care
  • The patient’s psychosocial and cognitive status

Standard: Conformance with physician orders
This standard ensures that home health agencies follow physician orders in accordance with law and agency policy. The final CoP modified this standard from the previous version, adding:

  • Verbal orders must be:
    • Documented, signed, dated, timed (time received)
      • By nurse/other qualified practitioner responsible for furnishing or supervising the ordered services
        (Note: Although CMS allows an LPN to accept verbal orders, 42CFR 409.43 remain in effect requiring that a plan of care include …”an attestation (relating to the physician’s orders and the date received) signed and dated by the registered nurse or qualified therapist…responsible for furnishing or supervising the ordered service in the plan of care)”
    • Authenticated and dated by the physician
  • HHA must promptly alert all relevant physician(s) to any changes in patient’s condition or needs that suggest that outcomes are not being achieved and/or plan of care should be altered

Standard: Review and revision of plan of care
This Condition of Participation standard states that a revised care plan must reflect:

  • Current information from the patient’s updated comprehensive assessment
  • Information concerning the patient’s progress toward the measurable outcomes and goals

Revisions to the plan of care must be communicated to the patient, representative (if any), caregiver, and all physicians issuing orders for the plan of care. Additionally, revisions to the patient’s discharge must be communicated to the patient, representative, caregiver, all physicians issuing orders for the HHA plan of care, and the patient’s primary care practitioner or other health care professional who will be responsible after discharge.

Standard: Coordination of care
The coordination of care standards says that the home health agency must:

  • Assure communication with all physicians involved in the plan of care
  • Integrate orders from all physicians involved in the plan of care
  • Integrate services (directly or under arrangement)
    • Identify needs and factors that could affect patient safety and treatment effectiveness
    • Coordination of care by all disciplines
  • Coordinate care delivery to meet the patient’s needs
    • Involve patient, representative (if any), and caregiver(s) in coordination activities
  • Ensure patient, caregiver(s), receive ongoing education and training
  • Provide training to ensure timely discharge

Standard: Written information to the patient
This standard indicates that the home health agency must provide the patient and caregiver a copy of written instructions outlining:

  • Visit schedule
  • Frequency of visits
  • Patient medication schedule/instructions: name, dosage, frequency, including medications will be administered by HHA
  • Any treatments, including therapy services
  • Any other pertinent instruction
  • Name and contact information of the HHA clinical manager

Home health agencies will want to determine how they are going to provide this information to the patient. While it does not have to be a copy of the actual plan of care, it does need to be a document that outlines the above.

 

In the next blog article in this series, Mary will discuss updates to the Patient Rights requirements in the CoPs. Be sure to subscribe to our blog  to get notifications when new articles in this series are posted!

Have questions about the new CoPs? Read our FAQ that addresses home health agencies’ most common questions and concerns.

 

About Mary St. Pierre, RN, BSN, MGA

Mary St. Pierre worked was employed as a registered nurse by the Visiting Nurse Association of Trenton and St. Francis Hospital in New Jersey, followed by 24 years as a home care nurse, clinical supervisor and branch manager with the Visiting Nurse Association of Washington, DC (now MedStar VNA).

Before retiring in 2013 she oversaw the operations of the Regulatory Affairs Department of the National Association for Home Care & Hospice (NAHC) for 20 years, tracking regulations and influencing regulatory bodies (e.g. CMS, FDA, OSHA). She wrote articles, prepared educational programs, presented speeches and programs and kept the NAHC membership abreast of regulatory, Medicare coverage, quality, and clinical information.

Since retirement, Mary has served as a consultant, providing clinical, operational, and regulatory guidance to the home health industry. She currently provides services exclusively to HEALTHCAREfirst.

April 13, 2017

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