Proposed Medicare COPs could mandate closer ties
Proposed Medicare COPs could mandate closer ties
You may be working with the enemy
What if your agency were subcontracted by a home health agency to provide infusion therapy? The proposed Conditions of Participation (COPs) have left it unclear as to how the two entities would have to work together.
"I need further clarification from HCFA [Health Care Financing Administration], but certainly all the services within the organization would have to be coordinated with the physician," says Mary St. Pierre, National Association for Home Care’s (NAHC) director or regulatory affairs. "Ideally, even if it is a separate IV company that is billing them and providing services for patients, these should be coordinated closely."
The U.S. Department of Health and Human Services (HHS) in Washington, DC, recently jumped on the data collection/quality improvement bandwagon when it released proposed revised COPs for home health agencies participating in the Medicare program. Pending clarification from Washington, the proposals could call for care providers to coordinate care much more closely with one another than in the past.
The proposals include:
• requiring agencies and patients to discuss expected outcomes of care plans;
• requiring agencies to coordinate all care that physicians prescribe for patients;
• requiring criminal background checks on home health aides as a condition of employment.
The HHS also proposed to require the use of the Outcomes and Assessment Information Set (OASIS) for patient assessment, outcomes, and satisfaction.
The NAHC agrees with the intention behind the proposed standards.
"I think the overall gist or bent of the entire process is something we favor," says St. Pierre. "Focusing on assessment of the patient and quality improvement are approaches that we have favored."
Too soon to get specific
St. Pierre says it is too early to speak in specific terms on the potential impact of the proposed revisions on Medicare COPs. "We have to analyze each of the conditions and standards independently as well as how one relates to the other."
St. Pierre notes the OASIS proposal should not create conflict with the Joint Commission on the Accreditation of Health Care Organizations’ recently announced ORYX initiative. (See cover story, p. 57.)
OASIS not necessarily left out
"Although OASIS is not included on the published list from the Joint Commission, it is my understanding it will be," says St. Pierre. "The reason it was not included is because it is HCFA’s property, and they did not authorize its release in its final form to anyone until it was published in the Federal Register."
However, OASIS may run into difficulty gaining approval, says Patrice L. Spath, a health care quality and resource management consultant in Forest Grove, OR.
"The issue on something like OASIS is the federal government’s [difficulty in sharing] benchmarking data that is provider-specific with the Joint Commission," she says. A second problem area could be the difficulty gaining funding for the various fees associated with becoming an approved vendor and taking part in the program. (See story, p. 59.)
Don’t make costly mistake
Not every home infusion provider is Medicare certified. However, certified or not, you’d be wise to watch the proposed COP revisions/OASIS implementations unfold. If you do otherwise, you could be making a costly business mistake.
Mike Semon, RPh, pharmacist and president of Caring Solutions in Crestline, OH, says all home infusion agencies should consider expanding their focus and services to include Medicare.
"One of the pathways that we as infusion companies should take a look at is becoming a field home health agency to prepare for Medicare managed care," he says.
As recently as two years ago, Semon felt his agency could make a profit providing nothing but home infusion. He has since changed his mind.
"Medicare and Medicaid are going to a managed care flavor," he says. "To prepare for that, I think most people have to go for the skilled effect if they want to be a survivor."
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