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Are your patients willing to be bathing guinea pigs?<\/em><\/strong><\/span><\/p>\n More than four months into implementation of the drastically revised Home Health Conditions of Participation, home health agencies continue to struggle with the new regulations. And one of the changes proving most dangerous to HHAs\u2019 compliance is the change in 484.80(c)(1) regarding aide competency evaluations.<\/p>\n The requirement at 484.80(c)(1) Home Health Aide Services: Competency Evaluation spells out that a Registered Nurse must observe \u201can aide\u2019s performance of the task with a patient.\u201d The standard lists multiple tasks (see box, p. 123<\/em>).<\/p>\n The previous iteration of the CoPs also required RN observation of an aide performing the task, notes attorney\u00a0Robert Markette\u00a0<\/strong>with\u00a0Hall Render\u00a0<\/strong>in Indianapolis. But the former Interpretive Guidelines clarified that performance could be on a \u201cpseudo-patient such as another aide or volunteer in a laboratory setting.\u201d<\/p>\n Critical:<\/span>\u00a0<\/strong>Now, the new CoPs use the same \u201cpatient\u201d language, but the draft IGs for 484.80(c)(1) issued last November specify only that \u201cthe tasks must not be simulated in any manner and the use of a mannequin is not an acceptable substitute,\u201d which was also in the former IGs. There is no mention of a pseudo-patient.<\/p>\n This difference is arguably the CoP change presenting agencies with the biggest challenge to compliance, says\u00a0Melissa Abbott\u00a0<\/strong>with\u00a05 Star Consultants\u00a0<\/strong>in Camdenton, Missouri. The areas that are most problematic are giving the patient a \u201cSponge, tub,\u00a0and\u00a0<\/em><\/strong>shower bath\u201d and \u201chair shampooing in sink, tub,\u00a0and\u00a0<\/em><\/strong>bed\u201d (emphasis added). The former CoPs said \u201cor\u201d instead of \u201cand.\u201d<\/p>\n To begin with, sending RNs out with aides in the field to demonstrate competencies \u201cis an exorbitant expense that we didn\u2019t have before,\u201d notes consultant\u00a0Kathy Roby\u00a0<\/strong>with\u00a0Qualidigm\u00a0<\/strong>based in Wethersfield, Connecticut.<\/p>\n And having aides make extraneous visits, when aides \u201care as scarce as hen\u2019s teeth,\u201d makes access to aide services even more challenging, Roby says.<\/p>\n But perhaps most problematic is that there simply are not enough patients on service who can take a tub bath for aides to be able to demonstrate on, Abbott says. \u201cIt is very unlikely that there would be a home care patient that requires a tub bath, as it usually is unsafe for the client and for the staff person involved,\u201d she notes.<\/p>\n What About Private Duty Patients?<\/strong><\/span><\/p>\n HHAs have been trying to get creative to overcome this compliance challenge, but their options are limited.<\/p>\n Strategy #1:<\/span>\u00a0<\/strong>If there is someone on service who does get a bath, rotate your current aides to visit the patient in order to get competency completed, Abbott advises.<\/p>\n The problem:<\/span>\u00a0<\/strong>Patients can refuse to bathe if they wish, Markette says. And even when they are willing to let their own regular staff bathe them with their regular nurse observing, they generally hate being used as a \u201cguinea pig\u201d for multiple different aides to bathe, he adds.<\/p>\n Having aides demonstrate competencies on current patients only for tub bathing \u201cis not a real solution,\u201d Markette says. Instead, it\u2019s an idea that\u2019s only workable \u201cin the ivory tower\u201d of CMS \u201cin Baltimore,\u201d he criticizes.<\/p>\n Strategy #2:<\/span>\u00a0<\/strong>HHAs with a private duty unit have broached the idea of conducting the evals on their private duty patients, who may be in better health and thus more likely to be able to take a tub bath safely, Markette relates.<\/p>\n The problem:<\/span>\u00a0<\/strong>It\u2019s unclear from the new CoPs and draft IGs whether this would fulfill the requirement, since the standard says the task must be performed \u201cwith a patient.\u201d That language might mean a Medicare patient specifically, and\/or one under a current Medicare plan of care, Markette notes.<\/p>\n Strategy #3:<\/span>\u00a0<\/strong>HHAs also theorize that perhaps, if the aide does not have to perform a certain task, she does not have to be evaluated on it, Markette says. Therefore, if an aide has no patients who can safely bathe in the tub, she won\u2019t have to perform tub-related tasks for evaluation. If an aide did serve a patient needing tub baths, then an RN would evaluate her competencies in those tasks as the need arose.<\/p>\n The problem:<\/span>\u00a0<\/strong>Again, it\u2019s unclear from the CoP and draft IG language whether this would fulfil the requirement, Markette allows.<\/p>\n The high rate of turnover among aides, particularly in some geographic areas, exacerbates the unworkability of these strategies, Markette adds.<\/p>\n HHAs Hold Out Hope For Final IG Rescue<\/strong><\/span><\/p>\n As agencies struggle to comply with 484.80(c)(1), they also hope they may get some relief when CMS issues the final version of the IGs. If CMS would replace the \u201cand\u201ds in the task list with \u201cor\u201ds as with the previous iteration of the CoPs, the standard would be much more reasonable, Abbott says.<\/p>\n Or if CMS would go back to allowing aides to demonstrate competencies on pseudo-patients including peers or other volunteers, HHAs would no longer face insurmountable obstacles to compliance, experts agree. \u201cWe are hoping for clarity and correction in the final guidelines,\u201d Roby says.<\/p>\n Note: See the final rule on the new Home Health CoPs at\u00a0www.gpo.gov\/fdsys\/pkg\/FR-2017-01-13\/pdf\/2017-00283.pdf<\/a>. For a free PDF copy of the draft IGs, email editor Rebecca Johnson at rebeccaj@eliresearch.com with \u201cDraft IGs\u201d in the subject line.<\/em><\/p>\n Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":" Are your patients willing to be bathing guinea pigs? 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