Articles and Blogs

On September 28, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum entitled “Guidance related to the Emergency Preparedness Testing Exercise Requirements- Coronavirus Disease 2019 (COVID-19)” (“QSO Memo”) that confirms that certain testing and training exemptions are available based on activation of emergency plans and the... READ MORE

On March 13, 2020, Secretary Azar of the Department of Health and Human Services (the “HHS”) issued a letter titled “Waiver or Modification of Requirements Under Section 1135 of the Social Security Act” (the “Azar Letter”) that grants the Centers for Medicare & Medicaid Services (the “CMS”) the authority to issue waivers specific to... READ MORE

On March 10, 2020, the Quality, Safety & Oversight Group at the Centers for Medicare & Medicaid Services (“CMS”) issued a memorandum entitled “Guidance for Infection Control and Prevention Concerning Coronavirus Disease 2019 (“COVID-19”) in Home Health Agencies (“HHAs”)” (“QSO Memo”) that announced recommendations for HHAs regarding taking appropriate action to address potential and confirmed COVID-19... READ MORE

On January 13, 2017, CMS published the revised Conditions of Participation (“CoPs”) for home health agencies, 42 CFR 484, Subparts A, B, and Subpart C. The CoPs became effective on January 13, 2018. On August 31, 2018, the Centers for Medicare & Medicaid Services (“CMS”) issued a Memorandum to State Survey Agency Directors (QSO-18-25-HHA) that... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) released a draft of the Interpretive Guidelines (“Draft Interpretive Guidelines”) to the final Conditions of Participation (“CoPs”) for home health agencies that CMS issued in January 2017. The CoPs are scheduled to be implemented January 13, 2018. CMS has asked for feedback on the Draft Interpretive Guidelines. The Draft... READ MORE

Review of the New Home Health Conditions of Participation – Emergency Preparedness, Organization and Administration of Services, Personnel Qualifications and Clinical Records. This is the sixth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they... READ MORE

Review of the New Home Health Conditions of Participation – Patient Rights (part 2). This is the fifth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health... READ MORE

Review of the New Home Health Conditions of Participation – Patient Rights. This is the fourth article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes they proposed to make to the home health CoPs in... READ MORE

Review of the New Home Health Conditions of Participation – Infection Control and Prevention; Skilled Professional Services; and Home Health Aide Services. This is the third article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With the release of the Final CoPs, CMS is finalizing the significant changes... READ MORE

Review of the New Home Health Conditions of Participation – Release of Patient Identifiable OASIS information, Reporting OASIS Information and Comprehensive Assessment of Patients; and Care Planning, Coordination of Services and Quality of Care. This is the second article in a series discussing CMS’s Final Revised Home Health Conditions of Participation (“Final CoPs”). With... READ MORE