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This Minute reviews the four items that are being proposed for change in the Home Health Conditions of Participation, specific to home health aide supervision.

Hello Everyone, Welcome to our Monday Minute. Today I want to cover with you four proposed changes to the Conditions of Participation as they specifically relate to home health aide services. I’m sharing this today because the National Association for Home Care and Hospice is requesting feedback from agencies across the country in order to appropriately compile comments during the comment period for the proposed rule. So, there were four items, as I stated that they are discussing changing, regarding again, home health aide services. The first of those is that currently, we are required to conduct a home health aide supervisory visit every 14 days. Of course, there are some waivers to this during the Public Health Emergency, but these changes would be of course, in the routine regulation, not specific to the COVID-19 waivers. So, in this 14-day supervisory visit, the proposal is that agencies will be able to do at least or at a maximum, two supervisory visits via tele communication mode in a 60-day episode. The kicker is they are only allowing that virtual supervisory visit in situations where a supervisory visit was scheduled in person, but something happened, and it wasn’t able to be done or rescheduled. So, it would be on a need basis, and would not be something that you could just routinely schedule. Having the opportunity or the possibility of doing a supervisory visit, virtually when things did happen that caused you not to be able to do the live one, I would think would be helpful, but we need your feedback.

Number two, when a patient is receiving nonskilled services, meaning they’re not receiving skilled care just an aide, there is a requirement for a 60-day supervisory visit and the proposal includes that the aide would not need to be present in the home during that 60-day supervisory visit, if this proposal is finalized. The third change that they’re talking about making is when a patient is receiving skilled care, and the aide is in the home that the requirement be a semiannual supervisory visit on site. Currently, there is an annual visit on site required and that would not change, but they are proposing to add that additional one on a semiannual basis. So again, feedback needed. Lastly, they are talking or proposing to change the requirement when an aide has been found to have a deficiency in their competency during supervisory visits, or assessments. The proposal is that the agency would be able to do a competency evaluation after finding this deficiency on the deficient area only and not be required to do a complete overall competency evaluation of the aide. So those are the four things specifically that the National Association is looking for your feedback on.

In the wording of this Minute, we will include the contact information for Mary Carr at the National Association. She is the one that is gathering your comments information. We are always very thankful that the National Association and your state associations work so diligently to help make sure that all regulatory updates and requirements are going to meet the needs of patients and of course, the agencies that are taking care of those patients. Thank you all for participating today. It was great seeing some of you at the Financial Managers Conference last week and hoping to see all of you at a live State Association conference or the National Association in October. Thank you again and have a great rest of your week.

 

Additional Resources:

NAHC Call for Feedback:
https://report.nahc.org/nahc-seeks-feedback-on-proposed-changes-to-home-health-cops/

Mary Carr, NAHC Vice President, Regulatory Affairs: mkc@nahc.org