In the recently updated Conditions of Participation, CMS spells out what they expect from a QAPI program. Additionally, the final draft of the interpretive guidelines (IG) for the Home Health Agency Conditions of Participation (CoP) was released last month.
How can agencies use this already mandatory requirement to help prepare them for the expected changes coming in 2020 with the proposed Patient Driven Groupings Model (PDGM)?
According to the newly released IGs, agencies need to use their QAPI program to identify negative patient outcomes or processes within the agency that could be improved. Through the QAPI program and Performance Improvement Projects (PIPs), agencies can monitor and measure this data to evaluate and implement changes in procedures, policies and interventions. Now is the time to consider which QAPI programs are needed now AND will also help prepare for PDGM.
Functional Assessment Items on OASIS
Are these items being assessed correctly? Is your agency prepared for the new additional functional items coming with OASIS-D changes? What training is being done RE: accurately coding these items? Are improvements being demonstrated? If not, is it a coding issue or a clinical issue?
ICD-10 Coding Trends
Are you identifying errors with primary and secondary diagnoses within M1021 and M1023? Are co-morbidities not being identified? What training and PIP can you put in place now to mitigate these errors?
Are you currently tracking data RE: whether patients are admitting from a community or institution? Does your agency have an appropriate mix of referral sources? Has your agency thought about what would be considered an appropriate mix?
Asking questions will foster communication, shine a light on current practices, and illuminate need for changes to prepare for PDGM.
Our Home Health Division, HealthPRO Heritage at Home, is focused on supporting home health providers with consulting, management, and staffing services. Our experts offer guidance related to important upcoming changes that impact Home Health outcomes. To learn more, contact us at: firstname.lastname@example.org.
Written By: Melinda Rochetti, PT, DPT, RAC-CT, COS-C, Vice President of Quality Assurance and Compliance