As agencies finalize their updates to policies, procedures, and processes to comply with the Conditions of Participation (CoP) effective January 13th, it is a good time to remember that you should also review state rules (if your state has separate rules) and accreditation standards (if your agency is accredited). In fact, whenever there is a disagreement between any set of regulations, the agency must follow whichever is more rigid.

If your state has home health laws, make sure you check them before getting rid of policies on the Professional Advisory Group (PAG) or quarterly chart reviews. A quick search shows that the states of Florida, Illinois, Colorado, and Arizona have not changed their regulations to reflect the updates to the CoPs. Illinois and Colorado agencies will still be required to complete quarterly chart reviews and have their PAG meet at least annually until those regulations have been updated. Florida still has a quarterly chart review requirement and Arizona has a PAG annual meeting rule. This list is not inclusive of all states and is up-to-date as of the date of this article.

It is also important to follow up with your accrediting organization if your agency is accredited. The Joint Commission, the Accreditation Commission for Healthcare (ACHC), and Community Health Accreditation Partner (CHAP) have all updated their standards for surveys on or after January 13th. The ACHC has an easy-to-read outline of their new standards located here and CHAP has a series of webinars here.

We recommend appointing at least one individual, ideally a committee, to take responsibility for ensuring agency compliance with all new rules and regulations. This person/group should be tasked with reviewing Medicare CoPs, state regulations, and accreditation standards and recommending updates to the governing body on any policies, procedures, and processes that are necessary to meet these rules.

We work hard to keep you in compliance. Our recent update to therapyBOSS included features that address the requirements of the new Conditions of Participation. If you have an additional feature request to assist you with continued compliance, please reach out to us.