By ShirleyAnn Janulewicz RN, BSN, PHN
As per a webinar I attended which focused on 3 parts: Comprehensive Assessment, Care Planning, & QAPI, the key to succeeding with the new Conditions of Participation (CoP’s) is taking action now to prepare for these changes.
Per Medicare regulations, the Occupational Therapist (OT) is still not able to perform the comprehensive assessment to qualify the patient for Medicare, but can perform the successive assessments. Timeliness of completion of the assessment within 5 days is key, and the psychosocial aspect including a cognitive assessment is needed, because agencies now need to include the patient’s desires and goals in their assessment to make it more patient-centered. Also, the willingness and availability of caregivers must be documented, so involve Social Workers for resources. Update policies to reflect these changes, and ensure all staff are educated on these changes so everyone is on the same page with their understanding.
Care-Planning needs to be individualized for each patient, with documentation that the patient participated in the planning. Discharge planning must be started on admission and documented. Verbal orders must now be timed in addition to being dated, so train and educate staff to start this now so it becomes ingrained. Everyone involved in the care of the patient must be notified of any and all changes, and the patient must be given written instructions on the name and phone number of the Home Health Agency (HHA) Clinical Manager. Each agency will determine how best to notify the PCP signing the Home Health Certification and Plan of Care Form 485 of all the changes, be it weekly, biweekly or monthly.
The HHA Governing body is responsible for oversite of the QAPI program, with an initial update, then quarterly to annual updates. A HHA can utilize dashboards with Key Performance Indicators (KPI) with real-time data. A yes/no audit tool will help with tracking, and chart audits are important to identify weak spots in the agency. These will help trend and track data between clinicians to determine if the issue identified is across the board or confined to only a few clinicians. The HHA needs to perform a root cause analysis to determine how best to proceed. Although the reporting on the Performance Improvement Project (PIP) does not go into effect until 7/13/18, agencies should be choosing a topic and collecting documentation now, so when they have to report, they will be ready. Do the right thing, start now.
Reference: Webinar by Diane Link RN, MHA of BlackTree Healthcare.
