Hi there , I'm Jennifer Kennedy , the Lead for Compliance and Quality at CHAP , and welcome to this session of CHAPcast . I'm really happy to be back for our CHAPcast with my co-host , and that would be Kim Skihan . Good to have you back , Kim .
Thanks , jen , good to be here .
All right . So today , kim , we're going to talk about , if I'm not mistaken , the top 10 survey deficiencies for home health in 2024 . And you know , I know , it's really tough for home health providers . You know they got all of the , you know budget cuts and managing with .
You know future cuts and oh , by the way , you've got to stay compliant and survey ready at any given time . So I you know future cuts and oh , by the way , you've got to stay compliant and survey ready at any given time . So you know , I feel for them .
I feel that they're under a tremendous amount of strain , but you know they still , as organizations , need to maintain their quality , need to maintain their compliance , which means that , optimally , when you have a survey , you only have standard deficiencies or as few deficiencies as possible .
So you know , can we jump in to figure out what we're going to talk about today in terms of home health survey deficiencies ?
Sure , absolutely , and this is an area , as you know , certainly near and dear to my heart , but also to CHAP , because we do take survey and compliance seriously , but mostly as a learning experience for providers . As you said , providers are challenged with day-to-day operations and compliance and so many other .
You know issues that are going on , but compliance with regulation is something that should remain top of mind and ongoing , and one of the resources and that's what we're going to talk about today is our CHAP Top 10 Home Health Deficiencies , which I do want to thank our CHAP Center for Excellence for compiling this information and making it available to providers on
our website at chapincorg , under Resources and Survey Readiness . It's important to be able to see what the top 10 deficiencies are , which means the most commonly cited for home health agencies . This list is specific to CHAP , but it does correlate in many ways with what we had seen previously , with CMS's top findings as well , and these are standards .
When you look at them , they do correlate with several G-tags , which are again the CMS COPs and standards , so it does work to an advantage for a home health agency to really stay on top of what those top areas are .
Yeah , absolutely . You know . I think it's just wonderful that we're able to present every year this list of top 10 deficiencies , because I feel like an organization . Yes , you need to be tracking and trending what your own deficiencies are , but you need to see how you're swimming in a different or a larger pool , if it were , or you know , as an example .
So it's a great way to benchmark yourself . Plug into other data sources that maybe you have another benchmarking pool where you can use that as well . We feel like the more data that you have , the better you can attack your performance improvement issues . So I'm really proud that CHAP does compile this on an annual basis and put it out .
Absolutely , and as a value add there are tips for compliance . So it really is a great resource , you know , for folks to have as well . Jennifer , in looking at the top 10 for home health , we do notice that , again , many of the top 10 findings are related to the care planning and comprehensive assessment .
Do you have insight or thoughts as to why this is I'm going to call it a perennial favorite in terms of the findings that just keep you know coming up , both for us as well as for CMS ?
Well , that's a great question and I'll start and I'm going to pitch it back to you because you're the home health expert here and I have some or clinicians rather think of this as it's a piece of paper . It's a document I have to maintain because this regulation says so .
They're not really using it for what it is intended to be used as meaning , as this is the roadmap or this is the guide to providing care .
So if , kim , you were a Mrs Fiddlebottom's nurse and you had to step away because , let's say , a family emergency , and I , as the nurse , are going to step in , I need to look at the assessments and the plan of care in order to really pick up and provide seamless care for that patient , in whatever setting they're receiving their care .
So it's more than a document . It's driven by the assessment process , which I know OASIS is long and it can be timely and all of that . But all of that is really important getting all of that data in there in order to build the best individualized plan of care for that patient as possible .
So now I'm going to pitch it back to you and I want to hear your thoughts about care planning and assessment .
Well , absolutely , I think everything you said is spot on the key with care planning . The bigger challenge I see with home health versus hospice is that hospice has embedded in the regulations the requirement for interdisciplinary group right , the absolute requirement for IDG to be part of care planning and discussion .
There was still the responsibility of the RN to make sure that the care plan is implemented and a case management component to it .
But in home health , while the COPs , especially the revised COPs remember we had the change , the update this past year , you know 2024 was a banner year for home health with the revised COPs , you know more expressly describing the interdisciplinary team , if you will , but there still is not that mandate that is in place .
As far as frequency of meetings and communication In home health , when you have especially different disciplines or , to your point , handoffs , you know , between even you know , nurses , if you will , there needs to be that oversight and communication and coordination to make sure that the care plan is reflective of all of the patient's needs , the patient's needs and the
coordination of care and services , to make sure that any changes in status are addressed in a timely manner and that the team is aware . And that , to me , is the biggest challenge with home health .
The individualization of care plans is always an issue , mostly because of when organizations are not optimizing their EMR usually their electronic medical record and really putting in additional information to make the care plan specific to a patient , that sometimes that can become an issue .
And then connecting the dots between the assessments , both initially and ongoing , and the care plan and making sure that care , treatment and services is being implemented . It's a challenge .
It is a challenge and I agree to all these Check , check , check challenge and I agree to all these check , check check . So let's connect some more dots . When you look at CHAP's top 10 , deficiencies .
What are some of the other things that you're seeing in that list ? So we do see as usual again , for both federally and CHAP , when it comes to home health , infection prevention and control . So just reminders that most of those findings are related to home visits hand hygiene , a bag technique , et cetera .
So when organizations are preparing and conducting mock surveys , really in-home observation is key to that . To observe that requirement , home health aides , providing services as included on their care plan , again seems to be a perennial topic as well . I know I can see you pursing your lips .
Can you .
Yes , I can , jennifer and I have had a long , long history of conversation about AIDS being any AIDS services , AIDS documentation , AIDS supervision being on the top 10 . We really would like for every home health agency and every provider to make a concerted effort to get this off of the top 10 . Yeah , let's make that the goal .
Yeah , the other thing is and this is something that actually is a little bit surprising for me , especially when I look again , again at the new you know the changes in the standards , but the language in the standards hasn't changed .
So the technical requirements of the patient rights document , what needs to be included , as well as the written information that needs to be provided to the patient . That requirement has been in place since 2018 , when the COPs were first revised , and it continues to remain a top .
It's not only in the top 10 , it's our top two , it's our second most highest citation , and these are what I call technical requirements that that organizations really need to make sure that they put those in place . Um , you know , across the board .
Yeah , All of that is extremely important , you know , and it's it's part of being survey ready really at any given time .
So we know that providers are going to have deficiencies and , um , what can we tell our providers out there about strategies that they can utilize or put into place to help improve some of those things we're seeing on the top 10 , but also , you know , being overall survey ready .
So you know many survey readiness and compliance tips and certainly , like I said , the Home Health Deficiencies document has tips for compliance .
But it's most important that organizations have ongoing survey readiness processes , not just when they are ready , think they're in the window or six months from their survey , because , as we know , complaint surveys can happen at any time and with changes in staff and management there are always , you know , opportunities to remind staff and also have them more comfortable
with the survey process .
So that needs to include all of the aspects that are in Appendix B that really do provide an outline when you look at information gathering and the beginning of Appendix B , great outline on how to conduct a mock survey so that you can monitor those areas ongoing and make sure that opportunities identified are incorporated into your QAPI program are incorporated into
your QAPI program .
The other topic that , as looking at this as so many years with assessment and care planning as top deficiencies and what we see in the field , it really is important for organizations to make sure that the RNs and the therapists for therapy-only cases do understand the principles of case management and their role as a case manager , that formal structure required , if
you will designated , you know , idg component , even though they are , you are required to have an interdisciplinary coordination and team involvement . It's really important because the clinicians who are coming into home health many are coming without prior home health or case management experience if they're coming from a facility or a role that involves shift work .
And when we're outside of bricks and mortar , you really are relying on the eyes and ears of all the people the clinicians and the aides who are in the home to work together to make sure , in conjunction with the physician , that all the patient's needs are being met and that any identified issues assessed are incorporated into the care plan .
And that's a skill that needs to be developed with the staff , because not all RNs and not all therapists are case managers . They can perform the skills you know and may conduct care , treatment and services or perform them , but they may not be able to effectively case manage . So that brought me to think . That got me to thinking that this would be .
I think this would be an excellent topic for a future chap cast to really discuss in more detail the principles of case management and the role of the case manager . What do you think , jessica ?
Yeah , I absolutely agree . I think there should be case management university . Agree , I think there should be case management university . When you come to the home-based care setting , you have to go to case management or care management 101 , right , because you know , organizations orient nurses and therapists different ways to how to be a care manager .
So there should be some standardization there in my mind at some point . So , yeah , I love the podcast . Let's start planning today , when we're finished here . That'd be great .
Sounds good .
All right , Kim , your number one takeaway from today .
Ongoing survey readiness , using the data that we provide , as well as other source data that an organization may have with our top 10 deficiencies , your own agency's previous survey history and making sure that you have that ongoing proactive survey readiness program to be able to make sure that you are in compliance with the conditions of participation and the standards
well in advance of an unannounced survey .
Yep , totally agree with that and I would say do not be afraid to sashay your way through Appendix B , because the interpretive guidelines are a gift from CMS and basically say what is going to happen in a survey and what is going to be looked for . So sashay away , as it were said , through that Appendix B . Any other parting thoughts , kim ?
be Any other parting thoughts , kim . No , I think that you know , just go forth and continue to conquer and , you know , do the great work that you , as home health providers , are doing out there and just make a difference every day with your patients' lives , day with your patients' lives Excellent .
That's great takeaway thoughts and be sure you can look at on the webpage for CHAP . We have a number of different resources available not just our top 10 , that can help you be a more successful and quality provider . So with that , we're going to sign off for today . Provider . So with that , we're going to sign off for today .
Thanks for all you out there taking time to plug into our podcast today From Kim , me and the entire CHAP staff . Keep your quality needles surging forward , stay safe and well , and thanks for all you do .