Agencies struggle with plan-of-care requirements

Fifteen percent of Medicare home health agencies were cited for the same certification deficiency on three consecutive surveys, according to a report issued by the Office of the Inspector General in the Department of Health and Human Services. Most of the agencies included in this group were located in six states: California, Florida, Illinois, Iowa, Michigan, and Texas.

Compliance with plan-of-care requirements presented the biggest challenge, with almost half of the cited agencies not demonstrating that the patient's physician reviewed the written plan of care. Other plan of care-related citations included: not covering all diagnoses, not alerting physicians to changes in patient's condition, not following the plan of care to administer drugs and treatments, and not coordinating and supporting objectives outlined in the plan of care.

"Meeting the compliance standards related to the plan of care is a difficult area for all home health providers," says Trish Tulloch, RN, BSN, MSN, HCS-D, senior consultant for RBC Limited, a Staatsburg, NY-based home health consulting company. The most common reason for not following the plan of care is an inability to access the most up-to-date information, she explains. "About 40% of home health agencies are still using a manual, paper-based system," Ms. Tulloch says. "This means that updates to the plan of care might take several days as clinicians turn in notes, get approvals, or have data entered into the record," she explains.

If the plan of care can be updated at the home of the patient, during the visit, the next clinician to visit the patient has up-to-date information, Ms. Tulloch points out.

An automated system may assist the process of maintaining and communicating an updated plan of care, but it does not ensure that your agency will meet all compliance requirements, Ms. Tulloch points out. If your clinicians don't update the records on their laptops by downloading updates at the start of each day, or if they don't transmit updated information at the end of the day, the current information is not available to them or the next clinician to visit the patient, she explains. To ensure the use of the most updated plan of care, policies must be clear about procedures related to the plan of care, she says.

Clinicians at South Davis Home Health in Bountiful, UT, know expectations related to plan of care when they are hired, says Denise Cook, RN, quality assurance and quality improvement coordinator for the agency.

"Establishing a plan of care, charting to the plan of care, and following the plan of care are part of their job requirements and are included in their annual competencies," she explains.

For the complete article, see the November 2008 issue of Hospice Management Advisor, published by AHC Media LLC,