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Did You Jump On Board With Medicare COP Changes Or Just Cross You Fingers And Hope For The Best? Time To Tackle Them Like A Lion And Be Prepared For Survey!


When the Medicare COP changed in 2018, it was assumed that the industry fell in line with regulation changes. However, as a national consulting agency, Kenyon Homecare Consulting found this untrue. There seem to be agencies that misunderstood the regulation changes or misread what the changes were. Here, we will highlight some of the changes that still seem to be missing in agencies today and why it will hurt you at survey.

Patient Rights:

Under the Medicare COP, it is required that the patient receive a written copy of the schedule of care, medications, pertinent instructions, care plan, and contact information for the clinical manager. The COP also requires an individualized Emergency Preparedness Plan. Reality is that some of these items have been a part of the Medicare COP prior to the changes, but without enforcement of the rule. This is no longer the case.  So, here are the frequent items we see when entering an agency:

  • Medications: The list of medications has not been provided to the patient or it is not written terms understood by the patient. Many lists still contain abbreviations such as BID, QD, or PO. These terms that are recognizable within the medical industry are not known to the patients we serve.
  • Schedule Of Care: Surveyors ask to see the schedule of care that was provided to the patient while doing in-home visits. Many agencies have not committed to the operational changes for clinical staff to get the schedule of visits in the hands of the patient. It is required that the patient is aware of when the disciplines will be in the home. As changes happen, you must inform the patient and document that it was done. In addition, we see that the month of admission may be on a calendar in the home, but the subsequent months are missing. Use your EMR to give reminders to clinical staff to update the next month of visits as appropriate.
  • Copy Of The Care Plan: This is still missing for many agencies. The patient has the right to see and know exactly what is on the individualized care plan. Surveyors will ask to see these things. We often hear from agencies that a copy of the care plan was given after admit, but the patient threw it away or that it was lost by the patient. We recognize these things happen. However, understand that your surveyor will expect that all clinical staff understand the regulation and procedure within your agency as to how your comply with this patient right. Another issue is that only the admission care plan is provided. As changes occur, the patient is to receive an updated copy. This is not happening in many agencies.

Emergency Preparedness:

This is still a huge deficiency for many agencies. Many times, we are consulted after surveys when the agencies have already received deficiencies. Now, they are in a crunch to fix what is broken prior to the surveyor returning to reassess the plan of correction. This requires education and operational changes ASAP. The reality is that many had a “plan”, but it was not completed with a hazard vulnerability assessment or with any education to staff. Many agencies had components of the plan but missed any memorandum of understanding with supporting agencies. It is not uncommon that there was no real process to determine surge or re-evaluate it.

These are all issues when it comes to survey time. There must be yearly evaluation and re-evaluation as necessary for your plan. the employees must be educated yearly and as needed. Drills need done routinely and employees need to know how to address mass communication methods when the needs arise. Many agencies will initiate a mass texting drill with low percentage of employee contact back. However, no changes were made to improve that or educate employees who did not respond to the drill. The issue lies in doing nothing with the data you receive from the drills. Agencies are often not yet a part of community disaster drilling and this is important if it is done in your area.

Let Us Help Be Your Path To Compliance:

If you find yourself behind the eight ball with survey coming, then let’s get the education and interventions in place to allow for compliance before you are hit with deficiency. Need help writing, updating, drilling, or educating staff on the emergency preparedness plan? If so, then we can help. Call Kenyon Homecare Consulting today at 206-721-5091 or contact us online to see how we can become your headquarters for compliance. If you need an updated manual that has all the changes present, you can purchase the online manual and edit the items specific to your agency. This will help you begin your process instead of working from behind with something outdated.


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