Comprehensive Assessment of Patients, Skilled Professional Services, and Home Health Aide Services

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 through three of our blog series on the Home Health Conditions of Participation (CoPs), we discussed QAPI, infection control, care, planning and coordination, as well as patient rights requirements. In this article, Mary will explain the updated CoPs for comprehensive assessments, skilled professional services, and home health aide services. 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.

Comprehensive Assessment of Patients
This condition of participation had minimal changes. There were content requirements added, including psychosocial and cognitive assessments, as well as the requirement that you identify in your assessment patient strength, patient’s own goals, and their care preferences.

Information may be used to demonstrate the patient’s progress toward achievement of the goals identified by:

  • Patient
  • Measurable outcomes identified by the home health agency

Standard: Update of the Comprehensive Assessment
The following items have been added to current assessment requirements:

  • Psychosocial needs
  • Patient’s strengths, goals, and care preferences
  • Information that may be used to demonstrate the patient’s progress toward achievement of the goals (patient and agency)
  • Patient’s primary caregiver(s), if any, and other available supports
  • Patient’s representative (if any)

There was an addition to this standard allowing the resumption of care assessment to be made within 48 hours of discharge or on the physician-ordered resumption date.

Skilled Professional Services
With this CoP, CMS took all of the skilled professionals and put them under one condition, requiring compliance across the board, including skilled nursing services, physical therapy, speech-language pathology services, occupational therapy, physician, and medical social work services.

Standard: Provision of services by skilled professionals
This standard states that services performed by skilled professionals must be:

  • Authorized, delivered, and supervised
  • By health care professionals meeting qualifications at §484.115
  • In accord with the home health agency’s policies and procedures

Standard: Responsibilities of skilled professionals
The revised CoP goes on to itemize the responsibilities of skilled professionals as follows:

  • Ongoing interdisciplinary assessment of patient
  • Development and evaluation of the plan of care in partnership with the patient, representative (if any), and caregiver(s)
  • Providing services ordered by the physician in the plan of care
  • Patient, caregiver, and family counseling
  • Patient and caregiver education
  • Preparing clinical notes
  • Communication with all physicians involved in the plan of care and other health care practitioners (as appropriate) related to the current plan of care
  • Participation in the home health agency’s QAPI program
  • Participation in agency-sponsored in-service training

Standard: Supervision of skilled professional assistants
This standard is, for the most part, currently the same as what currently exists regarding the nurse, therapist, and social worker supervising any assistance.

Home Health Aide Services
There were several additions to the Home Health Aide Services Condition of Participation.

Standard: Home health aide qualifications (by employee or contract)
CMS has added to the standard to include CNAs who have completed nurse aide training and a competency evaluation program approved by the state as meeting the requirements of §483.151 through §483.154 of this chapter, and are currently listed in good standing on the state nurse aide registry.

They also made an addition to the home health aide training program to include that the program must address communication skills, including the ability to read, write, and verbally report clinical information to patients, representatives, and caregivers, as well as to other agency staff. In addition, the home health aide training program must address the recognition and reporting of changes in skin condition.

Standard: Competency evaluation
Added to this standard is the requirement that a home health aide must be evaluated by observing his/her performance with a patient. It can be a pseudo-patient as long as it’s a live person. It cannot be a mannequin.

Standard: In-service training
This standard had an addition that states that in-service training may be offered by any organization and must be supervised by a registered nurse.

Standard: Qualifications for instructors conducting classroom and supervised practical training
The qualifications for in-service have been modified slightly to say that the instructor must be an RN with a minimum of two years nursing experience, at least one year of which must be in home health care, or by other individuals under the general supervision of the RN.

Standard: Eligible training and competency evaluation organizations
Generally, the requirements remain unchanged, however home health agencies are responsible for ensuring that their chosen training and competency evaluation organization hasn’t been excluded from participating in health programs or hasn’t been debarred from any government programs.

Standard: Home health aide assignments and duties
This standard was updated to state that home health aide assignments must be assigned by an RN or other skilled professional. They must also be provided with written patient care instructions prepared by that RN or other appropriate skilled professional.

Additionally, if a patient is receiving skilled services, the home health aide must receive supervision by by an RN or other appropriate skilled professional familiar with the patient, plan of care, and written patient care instructions no less frequently than every 14 days. The supervising individual must make an annual on-site visit to the location where the patient is receiving care and observe and assess the aide while performing care. If a deficiency in aide services is verified during an on-site visit, the agency must conduct, and the home health aide must complete, a competency evaluation.

Lastly, home health aide supervision must ensure that aides furnish care in a safe and effective manner, including, but not limited to, the following elements:

  • Following the patient’s plan of care for completion of tasks assigned
  • Maintaining an open communication process with patient, representative, caregivers, and family
  • Demonstrating competency with assigned tasks
  • Complying with infection prevention and control policies and procedures
  • Reporting changes in the patient’s condition
  • Honoring patient rights

In the next blog article in this series, Mary will discuss Personnel Qualification Requirements, Emergency Preparedness, Compliance with Federal, State & Local Laws/Regulations, Organization/Administration of Services, and Maintenance of Clinical Records. Be sure to subscribe to our blog  to get notifications when new articles in this series are posted!

Questions about the Comprehensive Assessment of Patients, Skilled Professional Services, Home Health Aide Services, or the CoPs in general? Read our FAQ that addresses home health agencies’ most common questions and concerns.

HEALTHCAREfirst has created a helpful Home Health CoPs resource hub to give you the latest information through FAQs, guides, blog posts, and recorded webinars. This resource hub will be continuously updated as new information about the CoPs is released in order to make sure you have everything you need to be prepared.


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.