Understanding the New COPs

Happy New Year to all of you!  We hope you are all doing well.

First of all, thank you for all you do, it doesn’t go unnoticed.  Especially true over the holidays-again taking that extra patient, seeing a visit on a Sat and of course learning a new EMR system or two!  We have gotten some nice positive feedback from agencies about our clinicians - Thank you!

What is being asked of us as clinicians is unfortunately increasing all the time.  We are all aware of insurance companies approving less visits and taking longer to approve extensions.  This week a new set of conditions of participation (COP) takes effect.  Many agencies are instituting new standards to comply with these regulations.  Since we work with many different agencies, the way each one is interpreting and complying with these new COP’s will vary.  We must continue to be flexible and diligent to meet the needs of each agency while focusing on the most important part of our jobs, patient care.  I know it can be disheartening when all this takes us away from our real job of patient focused care, but it is the reality we now live in.  

We would like to make sure we are all on the same page regarding the new COP’s that went into effect January, 13, 2018.  As professionals I hope we can do the best we can to treat our patients, do great documentation and communicate and comply with each agency standards. 

Timeliness-- preferably 24 hours for the actual evaluation  (and never more than 48 Hours!) .  Right after the evaluation is done, the agency needs to be contacted to let them know the evaluation was done and what the plan of care is.  This has been universal among all the agencies.  Do not contact us, contact the agency.  Evaluation documentation needs to be fully submitted within 24 hours of doing the evaluation (and never more than 48).  Many insurance companies need these evals to get any auth past the first eval.  Some insurance approvals can take a full week to get further auth, so the longer the documentation takes the longer the auth will be.  Don’t forget some agencies require us to pull your notes out of Kinnser and manually send them and that also takes time.  

In order to be effective you will need to get contact information for the other care team clinicians.  Please call other members of the care team and document that you did!  If you need phone lists/numbers for clinicians, do not hesitate to call the agency, or please let us know, and we will work to provide that information to you!  All new patients need to be contacted the night before to set up appointments.  If you cannot contact the patient that night or early the next morning, please call the agency.  Many times they have a better number they forgot to send us or some other insight.  Either way, they want to know in that first 24 hours what is happening with their patients.  The new COP demands greater care coordination efforts and interdisciplinary communication to ensure all providers are focused on the patient’s individual needs.
  
New rule for agencies - discharge summary and/or oasis needs to be processed by the home health agency no later than 5 days from discharge.  That means it needs to be in our system, and it needs to be reviewed and approved, and at times we need to physically send it off.  If it takes the clinician 3 days, there is no way we can service our agency customers so they can have a coder check it and submit in 5 days.  For dc oasis-if you do not have the soc oasis, please just answer the best you can.  Most of the time we know the patient well enough to answer most questions, but the rest the coders will address.  There are many changes to the Oasis document.  If you do SOCs please watch the videos in the link below to familiarize yourselves with these changes.  You are responsible for your own education in this and the trainings can be submitted for CEUs.
    
Transfer oasis needs to be in and submitted within 48 hours of discovering a hospitalization.  If you discover this, contact the agency and they will let you know if you need to do the transfer oasis.   For some agencies, such as Saint Luke’s and Advocate, with the transfer/discharge summaries there is a smart text template or form for when a pt transfers or discharges (see powerpoint below).  All patients who are transferred or discharged must have the template filled out or it will go back to them for completion.  Transfers only have a 2-day turnaround, so these are especially important.  Discharges have a 5-day turnaround.  Our coordinators route the summaries to the physicians once these are complete.

A big topic at a meeting Laura attended was patient centered care.  It is a huge part of the new COP’s and will ultimately improve patient care as a whole.  Make each eval and goals individualized based on that patient’s unique needs.  This may require us to be more creative with our wording and think “outside the box”.  Please do not submit a plan of care of 2x4 or 2x5 for every patient.  Each patient should be treated individually. Many patients would benefit from 3x/wk for the first week or so because they have little support or they are at a higher risk of hospitalization.  We have had comments from agencies that too many of our therapists have the same frequencies.  I know 2 visits / week is easier to schedule but it cannot be about us and certainly that cannot be documented.  A md visit is not a reason for a MV.  Usually an MD appointment is known in advance and you should be aware because you are scheduling ahead of time.  A MV should not happen during the first 2 or 3 days of the week.  These should be made up.  If you have difficulty with your time getting them in, let us know.  We have more missed visits than any of the other staffing companies.  

We also need to meet the COPs requirement of notifying ALL doctors of ALL changes to care plans.  This means PTAs and COTAs you MUST be notifying the evaluating therapist of any changes.  For infection control-the main new item would be fulfilling the requirement to document if the patient has a new infection since the past visit.  In Kansas, Saint Luke’s has a form "does the pt have an active infection?”  to complete if this is applicable.

Every note has to be unique.  Every evaluation and note has to have skilled interventions.  It is not enough to check off evaluation at eval-must include treatment.  At evaluation is is important to document communication with MD, agency and other care team members.  It was also suggested to use the language “patient is in agreement with PT plan of care”.  Some EMR’s include this.  Also need progress towards specific goals for notes.  Please include full vitals on each note.  Most agencies require temps for each clinician, Please do them, and please call the MD if vital signs are out of parameters.  

Patients have to be informed of their rights and responsibilities at SOC.  Many agencies, including Saint Luke’s and Advocate are amending their SOC forms.  If you do SOC's, please verify that you have forms that reflect the new COPs. As part of the COP’s, the patient and a representative have the right to know their care plan, why they are getting therapy, go over mutual functional goals, come up with an appropriate time frame.  The calendar/folder needs to be filled out with your discipline, frequency, tentative schedule and updated weekly.  

There is a greater emphasis on progress toward patient care goals.  Are we documenting that our patients are getting better?  Home health agencies' progress toward achieving specific outcomes will be tracked and they will be required to participate in performance improvement projects at least annually that measure progress on identified problem areas.

Some exciting changes are in the works for Aptiva Therapy that will mean more new agencies and more referrals.  As always, if we are the best at what we do, patients and agencies will continue to seek our services.  For your reference we have attached a link to a videos from Axxess, a PowerPoint from Saint Luke’s and a PowerPoint from Advocate.  As always, please don’t hesitate to contact the office or any partner if you have any questions!

We look forward to working with you all in this new year!

​Laura Nilles & Melissa Hardesty

https://www.axxess.com/help/agencycore/medicare-conditions-participation/medicare-conditions-participation/

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