More Conditions of Participation
484.55 Condition of participation: Comprehensive assessment of patients.
Most agencies will not find it difficult to comply with the requirements in the Comprehensive Assessment because they are already assessing these areas. The fact that ‘Cognitive Status’ which is already included in the OASIS data set and ‘Patient Goals’ are now mentioned in the Conditions of Participation may be an indicator of exactly how serious Medicare is about changing their focus to a patient centered approach to care and outcomes as opposed to the more punitive approach of hunting for agencies that disregard regulations.
The biggest change regarding the Initial Assessment that I see is that the Occupational Therapist is now able to complete the initial visit if OT is the only service ordered by the MD and if the need for OT establishes Medicare Eligibility. Welcome to the world of Admits, OT’s.
Content of Comprehensive Assessment
- Current health; functional and cognitive status
- strengths, goals and care preferences
- Continuing need for home care
- Review of all medications (Identify potential adverse reactions, ineffective drug therapy, side effects, significant drug reactions, duplication and noncompliance with meds.
- Patients primary caregiver and other available support
- Willingness to provide care
- Availability and schedules
- Patients representative if any
- Incorporation of OASIS data
Recertification visits are still done within the same time frame (days 56 through 60 of episode). Resumption of care visits are done within 48 hours of the patient’s return to home OR on physician ordered ROC date.
Plan of Care
Patients are accepted for treatment on the reasonable expectation that the agency can meet medical, nursing, rehab and social needs in the home. Care plan must specify the care and services to meet specific needs identified in the comprehensive assessment.
Plan of Care contents
- All pertinent diagnoses
- Mental, psychosocial and cognitive status
- Types of services, supplies and equipment required
- Frequency and duration of visits to be made
- Rehab potential
- Functional limitations
- Activities permitted
- Nutritional requirements
- All Medications and Treatments
- Safety Measures
- Risk for Emergency dept visits and rehospitalizations
- Measures to mitigate risk of above
- Patient and caregiver education
- Specific interventions and education
- Measurable outcomes and goals mutually identified by the patient and agency
- Advance directives
- All orders
Each patient must receive a copy of their plan of care.
Additionally, each patient is to receive written instructions that include:
- Visit schedule
- Med list with names, dosages and any meds to be administered by agency
- Any treatments including those administered by agency or persons acting on behalf of agency including therapy.
- Any other pertinent instructions specific to the patient’s care needs
- Name and contact information of the agency clinical manager.
Revision of POC
There is nothing new here but something has been removed. There is no requirement that a 60 day summary be sent to the physician. It shouldn’t be needed if agencies abide by the following.
- The plan of care must be reviewed and revised by the physician responsible for the home health plan of care at least every 60 days .
- Agency MUST promptly alert relevant physicians to any changes in the patient condition or needs that suggest that outcomes are not being achieved and/or that the plan of care should be altered.
- Revised plan must reflect current information from updated OASIS and contain information about progress to goals.
- Revisions must be communicated to the patient, representative (if any), caregiver and all physicians issuing orders for the plan of care.
- Revisions related to discharge planning must be communicated with all of the above plus the patient’s primary care practitioner or other healthcare professional who be providing care for the patient in the community.
Conformance with MD Orders
- Drugs, services and treatments are administered only upon the order of a physician.
- Influenza and pneumococcal vaccines may be administered per agency policy developed in consultation with a physician, and after assessing for contraindications.
- Review the way your agency handles plans of care and ensure your process includes a mechanism for dissemination of information to all physicians writing orders for a patient. Review or develop a vaccine policy that allows for administration of flu and pneumonia vaccines according to a well-written protocol developed in conjunction with a physician.
- Most agencies will have to expand the collection of information related to caregivers and availability.
- Begin now to audit admissions for the requirements set forth in the CoPs.
- Begin reviewing admissions using a tool based on the new requirements. admission-review-tool.pdf Modify to fit the needs of your agency.
- Educate your staff.
More Later. And to think, we haven’t even looked at Quality Assurance, yet.