In the March update, several changes have been made to the Interpretive Guidelines for Home Health Surveys. From clarifications to comprehensive assessments to nuanced adjustments in infection prevention protocols, each change adds layers of complexity for agencies striving for excellence in home health care delivery.
G Tags
In this update, they’ve consolidated certain G tags, resulting in fewer available G tags overall. However, it’s crucial to note that when they combine G tags, they’re not removing or deleting any of the previous G tags.
Additionally, survey procedures are being incorporated into the tags. This addition aims to provide surveyors with clear instructions on how to assess each G tag. Moreover, it enables agencies to better prepare for surveys by understanding the specific approach surveyors will take.
Allowed Practitioners
Updates were made to the language regarding Allowed Practitioners, moving away from exclusive use of the term “physician” as done previously.
Condition Level Deficiencies
One notable change is the addition of a statement to several Conditions of Participation, which reads:
“The manner and degree of non-compliance identified in relation to the standard level tags for this condition may result in substantial non-compliance with this COP requiring citation at the condition level.”
It’s important not to misinterpret that the absence of the mentioned statement on a G tag doesn’t mean that the G tag or the Condition of Participation couldn’t escalate to a Condition Level Deficiency. In essence, even if the tag lacks the statement shared above, it could still be elevated to such a deficiency if deemed necessary by the surveyor. We anticipate that tags with this specific statement will likely receive heightened attention from surveyors, given CMS’s explicit mention of them possibly leading to a Condition Level Deficiency.
Infection Prevention and Control
The recent update to the Infection Prevention and Control Interpretive Guideline is noteworthy. While it’s common to include sources for Infection Control Standards, there’s now a requirement in the Interpretive Guidelines for surveyors to not only ensure that agencies have stated their source, but also to delve into why that specific source was chosen and how it best suits the organization’s practices.
Other updates were made to Infection Control and Prevention, a crucial aspect of ensuring compliance with Quality of Care. Please be sure to pay attention to these changes.
Home Health Plan of Care
Another notable alteration to the Interpretive Guidelines pertains to section 484.60 concerning the Home Health Plan of Care. The significant change mandates that the agency must now document all relevant diagnoses for the patient, specifically those related to the Home Health Plan of Care. Previously, diagnoses were required for every ailment the patient had, which could sometimes result in an extensive list of 30 to 40 diagnosis codes, as an example. It’s crucial to grasp that the Interpretive Guidelines direct surveyors to review your chart, ensuring inclusion of all pertinent diagnoses, with a focus on those most closely associated with the current Home Health Plan of Care.
They’ve also made it clear that you must include all medically necessary supplies and equipment for the patient’s care. Essentially, this means that if the patient has items like a wheelchair, walker, crutches, and canes at home, but they haven’t used the crutches in a decade and the cane sits unused in a corner while they only rely on the wheelchair and walker, only the wheelchair and walker would be listed on the Plan of Care.
Comprehensive Assessment/Medication Review
There have been clarifications to the Comprehensive Assessment Completion, particularly regarding the Medication Review. In the past, there has been considerable discussion and confusion surrounding this issue. The new Interpretive Guideline explicitly states that any discipline involved in treating the patient, whether it’s a skilled discipline or a registered discipline etcetera, is permitted to review the Medication Profile.
Previously, there was a focus on nurses conducting the Medication Profile review, regardless of the ordered service provider. However, this Interpretive Guideline explicitly states that any discipline identified by the agency as authorized to provide this service to the patient has the capability to review the Medication Profile.
The changes that have been made to the Interpretive Guidelines range in significance. However, collectively, these updates offer clearer insights into the upcoming Home Health Survey you may be preparing for.
At Healthcare Provider Solutions, our team includes CHAP and ACHC certified consultants who are eager to support you with understanding these Interpretive Guidelines. We’re also available to conduct Mock Surveys to help you prepare for your upcoming survey. Should you need any assistance with understanding the updates to the Interpretive Guidelines, or with Mock Surveys, please feel free to reach out to us.
Additionally, our upcoming two-day home health workshop is scheduled for August 6-7, 2024 in Nashville, TN. Teresa Harbour, the COO of CHAP, will be joining us for this event. Teresa will be speaking on Survey Preparedness during the workshop. Register to attend our HPS Alliance Home Health Workshop by clicking here.
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