- Direct the change. Assign a transition leader, such as the administrator, a compliance officer, or a quality assurance manager, to be the change agent.
- Use the tools at hand. Talk to your EMR vendor right away to discover what is being done to aid compliance. Is quality assessment and performance improvement (QAPI) information being added to the system?
- Learn, then learn more. Require that the transition leader attend a formal training on the new rules as they are currently understood, and then attend another training after CMS issues interpretive guidance.
- Time-map your transition. Prep for the transition by creating a specific timeframe for compliance. This will look different for an agency with a 3,000-person census versus one with a 30-person census. What does it look like for your agency?
- Analyze to prioritize. Perform a full agency gap analysis that includes a review of the org chart, all policies, procedures, processes, programs, and each department to identify where compliance gaps exist.
- Education is the name of the game. Educate, support, and manage staff while necessary changes are being made. Include implementation meetings and special focus on areas that historically have been difficult within the industry, such as coordinating services with other types of providers.
- Know your agency. Assess board strengths and weaknesses and address appropriately to ensure they can meet new mandates, such as reviewing QAPI initiatives.
- Build a budget. The Congressional Budget Office estimated that implementing the CoPs would cost an industry-wide total of $293.3 million in the first year. How can your agency use technology to help control costs?
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