Time is on My Side: Getting Ready for the CoP Challenge

On Friday, CMS announced a delay in the new Home Health Conditions of Participation (CoP) until January 2018. That should come as no surprise to anyone since, as of today, we have no interpretive guidelines and surveyors have not been trained regarding the new Rule.  Just like in that Rolling Stones song “Time is on My Side”, CMS has given us the gift of time and we need to take full advantage of it.

This delay is welcomed by all who have actually read the entire 374-page document released by CMS in January of this year. It is important that every single agency in the US take full advantage of this reprieve as a time of preparation. It will take at least 6 months to prepare.

We all remember ICD-10 and the back and forth with CMS with delays and resets.  Compared to these new CoPs, ICD-10 preparation was much simpler. This new rule changes everything. It is more than a paradigm shift in policy and procedure. Experts call it a ‘sea change’ that is unprecedented. Compared to changes in conditions we’ve all experienced in the past (i.e. OASIS), this is revolutionary and will shake our industry as nothing else has.

Be sure, every person in your agency will be affected.  From the receptionist to your Board of Directors, this rule will change the culture in our industry and change the way we do business. It will no longer be ‘business as usual’.

Not so long ago, we had ICD-9 to ICD-10 transitioning challenges. Much of what we planned for that transition can clearly be used in our strategy in the shift to the 2017 CoPs. For instance, GAP analyses, extended training of ALL staff, budgeting, job description changes, etc. will all be necessary when taking this journey from where we have been comfortable with for decades.

The July 13, 2017 enforcement date originally proposed by CMS would have been almost impossible to achieve. We have been given the gift of time. We need to manage this time well and plan our course. Even six months will be a short time frame to achieve everything we need to do.

The January deadline is unlikely to change. Understanding of the Rule and implementing the associated staff training, policy and procedure revisions, and hiring need to begin right away. This is a radical shift from the way we currently function.

You will be able to meet this deadline – but you may need help. It will be important for you to watch for the multiple training sessions QIRT has scheduled.  We will be offering education and tools to help you through the process.

Arlene Maxim, RN

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