Home Health Conditions of Participation: 5 Tips for HHCoPs Preparation

Over the past several weeks, home health regulatory expert Mary St. Pierre, RN, BSN, MGA has been breaking down the new Home Health CoPs, including:

While CMS has delayed the phase-in date for the Home Health CoPs to January 13, 2018, home health agencies should not cease or postpone preparation. Here are some HHCoPs Preparation tips from Mary:

  1. Read the revised Conditions of Participation. There is no substitute for actually reading the rule and the responses to not only understand what it says, but what CMS’ intent is behind the changes.
  2. Watch for the CMS release of Interpretive Guidelines. The Interpretive Guidelines clarify the CoPs providing definition and explanation of the regulations and will help to give you a clearer picture of what you need to do. As of publishing of this article, the Interpretive Guidelines have not yet been released. You should refer to the “Response” section of the forward of the notice for help interpreting new requirements.
  3. Identify the components of the revised CoPS that will require action by your home health agency. You may need to address job descriptions, qualifications, and duties. Additionally, you may need to create or amend policies, procedures, forms, and processes to address:
    1. Patient rights
    2. Care plan processes
    3. Aide training
    4. Create/conduct professional and home heath aide in-services
    5. QAPI program
    6. Infection control program
  4. Educate all employees and contractors on the revised CoPs so that they are clear as to why changes are being made and how it will affect them.
  5. Review state licensure and accrediting body (if you use one) requirements to be certain that changes made are not in conflict and that you comply with the most stringent regulation.

Have questions about the new Home Health CoPs? Read our CoP 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.