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Home Health CoPs – Potential Delay of Effective Date

A proposed rule has been published in the Federal Register that would delay the effective date of the updated Conditions of Participation for Home Health Agencies. The HHA CoPs “focus on the care delivered to patients to HHAs, reflect an interdisciplinary view of patient care, allow HHAs greater flexibility in meeting quality care standards, and eliminate unnecessary procedural requirements,” according to the document.

CMS received many comments that the new requirements would take more time for HHAs to adjust their resource allocations, staffing levels, and make any necessary infrastructure changes. Many comments also noted that HHAs felt they were not able to effectively implement the changes required until the new Interpretive Guidance has been released. As a result, CMS is proposing to delay the effective date of the HHA CoPs until January 13, 2018. It is currently set to become effective July 13, 2017. In line with extending this date, CMS also proposed changing two other significant dates in the final rule:

  • Performance Improvement Projects Phase-in: HHAs were provided with six months after the January 2017 HHA CoPs final rule became effective to collect the required data to start implementing data-driven PIPs. The revised phase-in date would become July 13, 2018.
  • Administrator “Grandfathering” Date: All HHA administrators that were employed prior to the effective date had been grandfathered in and did not need to meet the new personnel requirements. The effective date for this would become January 13, 2018.

View “Medicare and Medicaid Programs; Conditions of Participation for Home Health Agencies; Delay of Effective Date” in the April 4, 2017 Federal Register.

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