Home Health CMS Survey Manual Hot Off the Press!
The Essentials
CMS updated the State Operations Manual (SOM) and Interpretive Guidelines for the first time in FOUR YEARS! CMS’s SOM provides surveyors with specific survey guidelines- including different levels of survey, levels of G tags, questions to ask, and key items to observe for. These protocols are then followed by an item-by-item tutorial on the Conditions of Participation (COPs) and detailed interpretive guidelines. This resource ensures that surveyors are consistent in their approach- and makes sure that all agencies understand the COPs and are able to prepare for survey!
The Highlights
1. The surveyor protocols and instructions have been completely overhauled - resulting in 23 pages of red text, directing surveyors on the process of performing a survey and updated G-tag levels (standard survey, partial extended survey and extended survey).
2. The protocols have now also been joined by the COPs and their updated “Interpretive Guidelines”, providing further real life clarity around the COPs.
3. Lastly, a few COPs were changed or added during the last four years through the “Final Rule Making”, and these are now added to the SOM/Interpretive Guidelines for the first time. Examples of these changes are included on page 2.
Examples of the Newer Regulatory Changes Include:
G516 Who can perform initial visit when therapy only: § 484.55(a)(2)
When rehabilitation therapy service (speech language pathology, physical therapy, or occupational therapy) is the only service ordered by the physician or allowed practitioner who is responsible for the home health plan of care, the initial assessment visit may be made by the appropriate rehabilitation skilled professional. For Medicare patients, an occupational therapist may complete the initial assessment when occupational therapy is ordered with another qualifying rehabilitation therapy service (speech-language pathology or physical therapy) that establishes program eligibility.
G810 Occasional use of telehealth for aide supervisory visit: §484.80(h)(1)(ii)
The supervisory assessment must be completed onsite (that is, an in person visit), or on the rare occasion by using two-way audio-video telecommunications technology that allows for real-time interaction between the registered nurse (or other appropriate skilled professional) and the patient, not to exceed 1 virtual supervisory assessment per patient in a 60-day episode.
G814 Aide supervision in Unskilled patients: §484.80(h)(2)(i)
If home health aide services are provided to a patient who is not receiving skilled nursing care, physical or occupational therapy, or speech-language pathology services, — (A) The registered nurse must make an onsite, in person visit every 60 days to assess the quality of care and services provided by the home health aide and to ensure that services meet the patient’s needs; and (B) The home health aide does not need to be present during this visit.
G814 Aide supervision in Unskilled patients: §484.80(h)(2)(ii)
Semi-annually the registered nurse must make an on-site visit to the location where each patient is receiving care in order to observe and assess each home health aide while he or she is performing non-skilled care.
Next Steps:
ONE. Download the updated SOM/Interpretive guidelines: https://www.cms.gov/files/document/qso-24-07-hha.pdf
TWO. Concentrate initially on the “Surveyor Protocols and instructions”, noting the types of patients CMS tells the surveyor to choose during survey on pages 18-19.
THREE. Review the newer regulatory changes noted on page 2 (G516, G810 and G814) and ensure your agency policies and practices are reflective of these changes.