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The current Conditions of Participation (COPs), 42 CFR Part 484, went into effect in 2018 and have a specific focus for patient-centered, data-driven, outcome-oriented process that promotes high quality patient care for all patients. This focus reflects the following priorities:
These are priority areas of focus for accreditation surveys. According to the CHAP “Top 10 Home Health Deficiencies -2021”1, the areas where the most deficiencies (noncompliance) occurred were related to Subpart B, §484.50 patient rights and Subpart B, §484.60 care planning, coordination of services and quality of care which correlate directly with the priorities as outlined above.
This section focuses on patient rights notices and policies and is divided into several sections which outline specific requirements the HHA must follow. In brief, HHA must provide a written notice of rights and responsibilities in advance of care (or within 4 days of initiation of care to patient’s selected representative if applicable). The notice must be understandable to those with limited English proficiency and patients with disabilities and written confirmation of receipt is required. This notice must include the HHAs transfer and discharge policies, contact information of the administrator and the OASIS privacy notice.
A court-appointed “legal” representative or patient self-selected representative may elect to exercise the patient’s rights. The patient’s rights, in addition to being free from verbal, mental, sexual, and physical abuse, as well as injuries of unknown source, neglect, and property misuse, now require the patient to participate in their care related to care being furnished, disciplines providing care, visit frequency, goals and any changes in care being provided.
Patients must also be provided with written notice relating to change in payment or non-covered services.
This section focuses on the requirement that each patient have an individualized written plan of care that must include care and services necessary to meet the patient-specific needs, responsible disciplines, measurable outcomes and goals, and patient and caregiver training and training to facilitate timely discharge. Conformance with physician orders, and coordination of care delivery to meet patient needs is also a key focus of this standard.
Patient involvement in their Care Plan is a key provision where the HHA must provide the patient and caregiver a copy of written information which includes the visit schedule and frequency of visits, patient medication schedule and instructions, pertinent instructions and the name and contact details of the HHA clinical manager.
This is a very brief overview of two of the ten sections of Subpart B: Patient Care where compliance has been difficult. As Part 484 - Home Health Services includes 5 Subparts with several sections each, navigating the COPs can be daunting; future articles will dive deeper into the most difficult to master.
This blog was originally published as "Conditions of Participation — Back to Basics; How Do I Ensure Compliance " by Leigh Massey, RN, JD, WOCN, CHC, CHPC on July 20, 2022, for Maxwell Healthcare Associates. The Maxwell TEC editorial team has since updated this article to ensure accuracy and relevance.