CMS Releases Draft Version of the HHCOP Interpretive Guidelines

The Centers for Medicare & Medicaid Service (CMS) has issued a draft version of the home health Conditions of Participation (CoPs) Interpretative Guidelines (IGs). CMS issued the IGs to the National Association for Home Care & Hospice (NAHC) with a request for stakeholder feedback.

CMS is unable to entertain individual comments and requests that aggregated comments be submitted through NAHC. 

Home health providers have anxiously awaited the release the IGs to provide guidance for meeting CMS’ expectation for implementation of the revised CoPs.   Although CMS has previously stated that the final version of the IGs will not be available until December, the draft IGs provide some insight into the expectations for compliance.

The draft IGs includes some welcome clarifications, such as, not requiring that the home health plan of care be submitted to the physician every time a verbal order is received and that an associate degree is considered an undergraduate degree to satisfy the qualifications for the Administrator. However, there are still areas that require further clarification for which we plan to provide comprehensive and constructive feedback.

NAHC must provide CMS with feedback no later than COB November 15, 2017. Therefore, NAHC requests that comments be submitted to Mary Carr, V.P. for Regulatory Affairs at , no later than the COB on November  10, 2017.

NAHC appreciates CMS’ outreach to the home health community and the opportunity to review the draft IGs.