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Revised Conditions of Participation – Part 4


Two More Conditions of Participation

The next two conditions apply to the people who visit patients on behalf of your agency regardless of whether they are directly employed or contract personnel.

Skilled Professionals

Skilled professionals include nurses, therapists (Physical, Occupational and Speech) and Social workers.  The qualifications are expanded upon under another Condition of Participation, §484.115 Personnel qualifications.  So, this standard is as follows:

484.75 Condition of participation: Skilled professional services

Services are authorized, delivered, and supervised only by health care professionals who meet the appropriate qualifications.

Responsible for:

  • Ongoing interdisciplinary assessment of the patient;
  • Development and evaluation of the plan of care in partnership with the patient, representative (if any), and caregiver(s);
  • Providing services that are ordered by the physician as indicated 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 HHA’s QAPI program; and
  • Participation in HHA-sponsored in-service training.

Supervision

  • Rehabilitative therapy services are provided under the supervision of an occupational therapist or physical therapist
  • Medical social services are provided under the supervision of a social worker

Action:

  • Ensure that all employees are aware of responsibilities to QA program.
  • Begin involving entire agency now.
  • Clarify care coordination roles for nursing and therapists
  • Review recent charts for evidence of communication, patient teaching and collaboration. If unable to identify these elements, revise policies and educate staff.
  • When the above elements are identified, share the documentation with staff as examples of what is expected.

484.80 Condition of participation: Home health aide services

The requirements for home health aide services are  extensive.  The first section reviews what is to be included for agencies that train their home health aides.  Most agencies I work with hire home health aides who have a certificate from a trade school or hospital, etc.  Since the training requirements and competency requirements are very similar, I made you a short list of all the required elements.  home-health-aide-training.

This section is for the rest of you that hire qualified home health aides.  Your responsibility is to assess competency and supervise these valuable employees.

As an aside, you won’t find anything about criminal history background checks here.  This does not mean you do not have to run a background check that meets your state’s standards.  My go to guy for over 15 years Ernie of EF Research.  He pretty much knows everything about background checks and can run them faster than the state police in most cases.   If you know of any other resources, please post in comments.

Back to home health aide competency which is to be assessed before an aide is assigned patients.

Competency must include:

  • Communication skills, including the ability to read, write, and verbally report clinical information to patients, representatives, and caregivers, as well as to other HHA staff.
  • Observation, reporting, and documentation of patient status and the care or service furnished.
  • Reading and recording temperature, pulse, and respiration.
  • Basic infection prevention and control procedures.
  • Basic elements of body functioning and changes in body function that must be reported to an aide’s supervisor.
  • Maintenance of a clean, safe, and healthy environment.
  • Recognizing emergencies and the knowledge of instituting emergency procedures and their application.
  • The physical, emotional, and developmental needs of and ways to work with the populations served by the HHA, including the need for respect for the patient, his or her privacy, and his or her property.
  • Appropriate and safe techniques in performing personal hygiene and grooming tasks that include –
    • Bed bath;
    • Sponge, tub, and shower bath;
    • Hair shampooing in sink, tub, and bed;
    • Nail and skin care;
    • Oral hygiene;
    • Toileting and elimination;
    • Safe transfer techniques and ambulation;
    • Normal range of motion and positioning;
    • Adequate nutrition and fluid intake;
    • Recognizing and reporting changes in skin condition; and
  • Any other task that the HHA may choose to have an aide perform as permitted under state law.

Underlined tasks must be performed by observation of the aide with a patient.  The remaining tasks may be observed directly or competency may be assessed through oral or written exam.

Supervision

If home health aide services are provided to a patient who is receiving skilled nursing or therapies, a registered nurse or other appropriate skilled professional makes a visit no less than every 14 days.  The supervision visit must be made by a skilled professional who is familiar with:

  • the patient,
  • the patient’s plan of care,
  • and the written patient care instructions

If an area of concern in aide services is noted by the supervising registered nurse or other appropriate skilled professional, then the supervising individual must make an on-site visit to the patient’s home in order to observe and assess the aide while he or she is performing care. (Present Supervisory Visit).

If the deficiency in aide services is verified during an on-site visit, then the agency must conduct, and the home health aide must complete a full competency evaluation.   That’s three things.  Here they are again.  I like lists.

  1. A deficiency is observed during a supervisory visit
  2. The Supervising nurse or other skilled professional will perform a present supervisory visit, and if a deficiency is observed;
  3. The aide’s competency is assessed again.

For agencies providing home health aide services paid for by Medicaid, (waived services), the aide’s competency may be abbreviated to include only those tasks that are specific to the patient.

Actions:

  • Verify competency now
  • Educate nurses and therapists regarding elements of competency defined by new CoPs.
  • Determine how your staff becomes familiar with the patient and commit it to policy.
  • Improve your hiring process to exclude candidates who do not have the dedication required to meet and exceed your standards.
  • Double up on education.  It will be less expensive to improve your home health aide services than investigating multiple complaints and your patients will appreciate excellent home health aide services as opposed to merely adequate.

None of this will be difficult for most agencies but when considering the patient rights condition which includes complaints together with the supervisory requirements in the home health aide services condition, a bad hire could be costly.  I’ve known agencies to skimp on competency because of a sudden need for a new aide.  This can’t happen anymore.  It shouldn’t have happened in the past.

Stay tuned.  The best is yet to come.

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