Some states require home health agencies to complete a criminal background check on all new direct employees. Other states require staff complete fingerprint checks prior to hire. If you are a Hospice agency Medicare requires Hospice Agencies to complete background checks on all direct care employees and volunteers §418.114(d).
What does your state require and are you compliant?
If you are a home health business accredited by Accreditation Commission for HealthCare (ACHC) you are required to complete background checks on personnel that have direct patient care and/or access to patient records. ACHC prefers that the agency rechecks criminal background history and the National Sex Offender Registry on all personnel that provide direct patient care/services at least every 3 years.
ACHC requires the background checks to include:
- criminal background – these are to be obtained in accordance with state requirements. In the absence of state requirements, criminal background checks are obtained within three months of the date of employment for ALL states that the individual has lived or worked in the past three years.
- Office of Inspector General Exclusion List
- National Sex Offender Registry
Contact ICS to find out more information on what background checks your agency may need to complete in order to be compliant.
As of January 13, 2017 the Federal Register published the final rule for the Centers for Medicare and Medicaid (CMS) regarding changes to Home Health’s Conditions of Participation (CoPs). The changes in the new CoPs were to be effective July 13, 2017. This has now been delayed to January 13, 2018.
Changes in the new Home Health CoPs include:
1. Renaming and Renumbering three sections
General Provisions 484.1 – 484.2
Patient Care (Administration) 484.40 – 484.80
Organizational Environment (Furnishing Services) 484.100 – 484.115.
Several new standards have been combined or incorporated into the new CoPs, some standards have been eliminated and two new CoPs have been added.
Many of the changes include Infection Control, Emergency Preparedness, Quality Assessment and Performance Improvement (QAPI) and Patient Rights. If you are accredited by Accreditation Commission for HealthCare (ACHC), Community Health Accreditation Partner, (CHAP) or The Joint Commission (TJC) you may already be meeting some of these new requirements.
Agencies will need to update policies and procedures in order to be compliant as well as implement new processes. Contact ICS to find out more information on what your agency will need in order to be compliant.
On September 8, 2016, the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Agencies. This is required of all 17 Medicare provider and supplier types including Home Health and Hospice Agencies.Agencies must comply will all applicable Federal, State and local Emergency Preparedness requirements.
Implementation of the new regulation 484.102 Emergency Preparednesswas initiated on November 15, 2016. Agencies are expected to be compliant of the new regulation effective November 15, 2017.
Agencies must develop an Emergency Preparedness Plan that includes four (4) Required Elements.
These required elements are:
- Emergency plan
- Policies and Procedures
- Communication plan
- Training and testing program
Contact an ICS home health consultant to find out more information on what your agency will need in order to be compliant and/or to assist with developing your agency’s Emergency Preparedness Plan.