The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE

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Eleanore Stephens
5 years ago
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2 Today s educational presentation is provided by The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE sales@kinnser.com

3 About the presenter ARLENE MAXIM, RN Vice President of Program Development QIRT (Quality in Real Time) QIRT Floral Park, NY Birmingham, AL Troy, MI Battle Creek, MI

RADICAL CHANGE Likely to be Most Difficult CoP to Implement 484.

4 RADICAL CHANGE Likely to be Most Difficult CoP to Implement Care planning, coordination of services and the quality of care delivered (replaces the coordination of patient services now found in ) Will cause culture change.

484.60 Care Planning, Coordination of Services, and Quality of Care This is a new Condition of Participation. 1.

5 Care Planning, Coordination of Services, and Quality of Care This is a new Condition of Participation. 1. Specifies that the agency prepare a patient plan of care that will outline care and services necessary to meet the patient-specific needs identified in the comprehensive assessment.

484.60 Care Planning, Coordination of Services, and Quality of Care 2.

6 Care Planning, Coordination of Services, and Quality of Care 2. The outcomes anticipated as a result of the individualized/unique patient assessment would occur as a result of the development of the individualized plan of care and subsequently implementing its elements.

7 Patient Eligibility Stressed the importance of only accepting patients for treatment based on a reasonable expectation that medical, nursing, rehabilitative and social needs could be met in the patient s place of residence.

Individualized Plan of Care Plan of Care Stressing individualized patient care plans POC must include: Patient and caregiver education and training to facilitate timely discharge.

8 Individualized Plan of Care Plan of Care Stressing individualized patient care plans POC must include: Patient and caregiver education and training to facilitate timely discharge. Patient-specific interventions and education; measureable outcomes and goals identified by agency and patient (d)(5) an HHA must ensure that each patient, and his or her caregiver(s) receive ongoing education and training provided by the agency, as appropriate regarding the care and services identified in the plan of care.

9 Canned POCs Caution should be used with pre-printed canned plan of care worksheets and EMR recommendations.! Canned or recommended approaches to developing plans are not what CMS will expect. Each plan must be individualized, and documentation must be specific to each patient.

10 Care Expectations 1. Each patient would receive an individualized written plan of care. 2. Each plan of care will specify the care and services necessary to meet the patients needs, including patient and caregiver education and training the agency will provide specific to patient care needs. 3. The individualized plan of care would be revised or added to at intervals, as necessary, to continue to meet the patient needs. 4. The plan of care includes patient-specific, measurable outcomes as a result of the plan of care prepared.

484.60(a)(1) Care Planning Care Planning will be essential to delivering individualized care. 2017 Rule specifies unique and/or individualized/patient specific at least 48 times in current rule.

11 484.60(a)(1) Care Planning Care Planning will be essential to delivering individualized care Rule specifies unique and/or individualized/patient specific at least 48 times in current rule. Care Planning as an after thought in home health. Care Planning is most often done prior to establishing goals. Expect care planning be a team effort with all members involved-including patient and caregiver(s). Living/breathing document.

12 484.60(a)(1) Care Planning Items required Frequency and duration of therapeutic interventions Established and periodically reviewed, and signed by physician All pertinent diagnoses Mental, psychosocial, and cognitive status Types of services required Types of supplies and equipment Frequency and duration of visits to be made

13 484.60(a)(1) Care Planning Prognosis Rehabilitation potential Functional limitations Activities permitted Nutritional Requirements All medications and treatments Safety Measures to protect against injury Patient and Caregiver education and training to facilitate timely discharge or referral Patient-specific interventions and education; measureable outcomes/goal Information related to any advanced directives Any additional interventions/orders needed

14 484.60(a)(3) Care Planning For patients Post Hospitalization Standardized assessment of patient s level of risk for hospital emergency room visits or hospital re-admission. An individualized plan to mitigate identified risk factors that contribute to risk identified.

484.60(b) Conformance with Physician Orders Orders may only be taken by personnel authorized by state laws and regulations and agency internal policies.

15 484.60(b) Conformance with Physician Orders Orders may only be taken by personnel authorized by state laws and regulations and agency internal policies.! RN or other qualified practitioner licensed to practice by the state must document a verbal order in writing in the record. Documentation must include:! Signature! Time! Date

16 484.60(b)(4) Conformance with Physician Orders Verbal orders must be included in the patient s plan of care. If orders are faxed or electronically transmitted-those orders are also required to be included in the clinical record and plan of care. Require physician orders to be: Authenticated Dated Timed

17 484.60(e) Written Information to the Patient (5 items) Must provide in writing to patient and caregiver with a copy of written instructions outlining: 1. Visit Schedule, including frequency of visits by agency staff. 2. Patient medication schedule/instructions including: Medication name, dose, frequency of administration. Identify which meds will be administered by agency personnel. 3. Any treatments to be administered by HHA personnel and personnel acting on behalf of the agency. 4. Any other pertinent instruction related to patient needs. 5. Name and contact information of the Clinical Manager.

18 Frequency Response to comments by CMS indicated they not only will expect frequency to be documented in terms of how often a discipline will visit, but also refers to visit lengths and/or intervention lengths (for example 90 minute visit with 70 minutes therapeutic intervention and 20 minute heat application).

19 484.60(c) Review and Revision of the Plan of Care Physician must review and revise the plan as often as necessary but at least every 60 days. The agency must notify the physician if: any changes in the patient s condition occurs or that measureable outcomes are not being achieved

20 484.60(c) Review and Revision of the Plan of Care Agency should revise the POC when necessary to: Reflect current information from the patients updated comprehensive assessment. Record patients progress toward meeting patient specific, measureable outcomes and goals. Agency to notify the patient, representative, caregivers, and the physician when the POC is updated due to a significant change in the patients health status-including discharge.

21 Improper Certifications by Physicians

22 Identified Risks for Incomplete Plans of Care Incorrect coding Improper sequencing of coding Medications listed inconsistent with medications in home or in other parts of clinical record (i.e. visit notes) Frequencies inconsistent with patient condition Generalized PRN orders - PRNs must be specific to patient condition Orders not followed Goals are not individualized for patient/excessive number of goals/sanctions Physician signature not signed in timely manner No estimated time for recertification(s)

23 484.60(d) Coordination of Care Agency must integrate services directly or under contract. Must assure that patient needs and factors that could affect patient safety and treatment effectiveness. Assure coordination of care provided by all disciplines. Communication with physician.

24 484.60(d)(3) Coordination of Care Expect coordination of care involving patient, representative and caregivers. Each patient and caregiver receives ongoing training and education from the agency regarding care and services identified in the POC and that patient and caregiver are expected to implement. Agency is expected to ensure training is completed for timely discharge.

25 484.60(d)(3) Coordination of Care CMS expects the agency to coordinate the nursing, therapy, aide and social work services. Agency s must be in communication with all physicians who are writing orders re: POC Agency must assume the role of care coordinator when dealing with multiple programs-i.e. cardiology, wound care, diabetes, etc.

26 484.60(d)(3) Coordination of Care CMS guidelines for coordination:! Coordination of care entails assuring that patient needs are continually assessed, addressed in the plan of care, that care is delivered in a timely and effective manner, and that goals of care are achieved.! HHAs may document these activities in a manner that suits their needs to demonstrate compliance.

27 484.60(d)(3) Coordination of Care DISCHARGE REQUIREMENTS! CMS has withdrawn requirements for discharge summaries.! Have proposed a separate rule Medicare and Medicaid Programs; revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies Nov. 3, 2015 (80 FR 68126).! Will implement discharge planning provisions of the Impact Act and will address the content of the discharge summary.

28 SUMMARY Upcoming surveys will be challenging.! Surveyors have not yet been trained on new conditions.! Know the conditions! If you do not know the conditions, you will be vulnerable to rogue surveyors and their decisions. Sanctions are likely to increase.! Already seeing an increase number of sanctions being imposed during surveys nationwide! Understand immediate jeopardy and triggers in Appendix Q Risks for the unprepared agency are significant.! Prepare all staff.! Understand what you will need to do to prepare.! Train now. Time is short.

29 REFERENCES CMS Open Door Forum. Presented by: Stephen Chahn Lee, Assistant United States Attorney (ND-IL) Medicare-FFS-Compliance-Programs/Pre-Claim-Review-Initiatives/Downloads/Special- Open-Door-Forum-on-Home-Health-Fraud.pdf

30 REFERENCES Discharge Planning For Information on Aging and Disability Resource Centers (ADRCs): For information on Centers for Independent Living (CILs): For information on Area Agencies on Aging (AAAs):

31 REFERENCES (as well as through a 24/7 Helpline at ) DISCLAIMER: QIRT (Quality in Real Time ) Presentations are intended for educational purposes only and do not replace independent professional judgment. Statements of fact and opinions expressed are those of the participants individually and, unless expressly stated and identified to the contrary, are not the opinion or position of the bodies that govern and regulate healthcare.

32 CLINICAL EDUCATION QUALITY Questions? Comments? Contact us: Floral Park, NY Troy, MI Birmingham, AL Battle Creek, MI Tel: (248) Fax: (248) FINANCIAL COMPLIANCE 39

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34 Request a demo of the Kinnser solutions that will help your agency succeed kinnser.com/requestademo sales@kinnser.com

Today s educational presentation is provided by. The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE

Today s educational presentation is provided by The software that powers HOME HEALTH. THERAPY. PRIVATE DUTY. HOSPICE At Kinnser, we believe post-acute care businesses need the right software solution for