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What Home Health Agencies Need to Know About CMS’ New CoPs

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On Friday, July 7th, The Care Centers for Medicare & Medicaid Services (CMS) announced a final rule delaying the effective date of the new Conditions of Participation (CoPs).

The CMS understands Home Health Agencies (HHAs) need time to plan, test, train, and implement new solutions to comply with changes. This announcement means HHAs will have until January 13, 2018 to meet new requirements. This new implementation date is six months after the original July 13th date.

Industry reaction to news of the delay has been positive. The change in start date is good news for HHAs, giving them more time to prepare for the changes. Considering this is the first change to CMS’s CoPs in nearly 20 years, HHA’s may feel overwhelmed with the changes. To help prepare, we have outlined a few key changes in addition to ways agencies can start preparing for the changes.

What do HHAs need to know?

    • 1. The Interpretive Guidelines
    • The Interpretive Guidelines clarify and explain CoPs. CMS announced a final draft of the guidelines will not be published until December 2017. The late publication will not affect the set implementation date. A draft of the guidelines is in progress and may be available this fall; However, agencies should not wait for the guidelines to be published to start preparing for the changes.
    • 2. Performance Improvement Projects (PIP)
    • The new CoPs include various Quality Assessment and Performance Improvement Strategies (QAPIs), including data-driven PIPs. This means agencies will have to gather information systematically to define issues and document projects. PIPs can focus on any spectrum of care, from prevention to post discharge. However, PIPs will be phased in slower than other QAPI conditions, with a July 13, 2018 deadline.

What actions should HHAs take?

    • 1. Plan and Review
    • a. Start the process of reviewing the new conditions so when the interpretive guidelines are published, your organization will be prepared.
    • 2. Identify Improvement Areas
    • a. Start collecting patient data in order to identify problem areas for PIPs. Look into technology that can assist with the collection of data efficiently.
    • 3. Train and Prepare
    • a. Put in place training and educational materials and/or programs so that staff members both patient-facing and non-patient facing are prepared.
    • b. Additionally, should you need to implement any changes to current patient interactions, be sure to proactively communicate and engage patients to inform them of any changes such as upcoming visits, treatments administered, etc.

Many HHAs will need to restructure or reorganize in order to stay compliant. Effectively engaging with hundreds of patients can be both time-consuming and expensive for agencies. Technologies like CipherOutreach can assist agencies make impactful patient engagement by being able to reach 100% of your census. CipherOutreach can also help with the collection of data to meet PIP requirements through executive reporting. HHAs can use the reporting to identify gaps in care, areas that need improvement, and keep track of what they have successfully improved.


To learn more about how CipherHealth can help home health agencies meet the new CoPs requirements, contact us today.

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