Proposed revision of COPs focus on quality of care

The proposed Medicare Conditions of Participation (COPs) promise to increase the load of nurses’ paperwork — as if they didn’t have enough already. It took the Health Care Financing Administration (HCFA) more than 58 pages just to explain what they were changing and why. Add into that the Outcomes and Assessment Information Set proposal and 79-item survey tool, and you’re well above the 100-page mark just to keep up with what’s going on.

The COPs revision is based on four core requirements: patient rights, comprehensive assessment, patient care planning and coordination, and quality assessment and performance improvement. Some of the more significant changes in the COPs proposal are:

• a requirement for criminal background checks of home health aides as a condition of employment;

• a requirement that within three years, Home Health Agencies must provide at least 50% of total skilled professional services directly;

• a mandate to implement the Outcomes and Assessment Information Set to collect outcomes data.

Other specific steps are:

• Current qualifications of home health aides should be expanded to include nurse aides who have completed appropriate nurse aide training or competency evaluation requirements.

• Agencies must discuss with patients the expected outcomes of care so patients can be more involved in care planning.

• Agencies must coordinate all care that physicians prescribe for their patients, thus preventing the current practice of several agencies serving one patient without care coordination.

• Agencies must provide their staffs with continual feedback on qualifications and performance as part of their continuous improvement programs.

Published in the Federal Register on March 10, the proposed COPs will be made a final rule by HCFA following the 90 days of discussion scheduled to end June 9.