• Michael Giudicissi

New Discharge COPs & What They Mean To You

William James, the father of American psychology famously wrote:

"Do everyday something you would rather not, so that when the hour of darkness comes, it will not find you unprepared"

While I put the quote in more modern language than James did, the intent and sentiment is the same. Over the past 13+ years of my home care sales consulting career I have coached and implored agency reps to do the things they naturally avoided, knowing a day would come when they would no longer be able to avoid them. I've taught and mentored reps and agencies to sell their agency's capabilities more professionally and to stop the focus solely on "relationship building".

That day has arrived.

Below is a newsletter excerpt from Elizabeth Hogue, Esq. Elizabeth has spent her entire professional career in the home care industry and is on the leading edge of regulatory changes, reform, and legal challenges. Here's what she said....

The Centers for Medicare and Medicaid Services (CMS) has issued new Conditions of Participation (COPs) for hospitals and home health agencies. These new rules are effective on November 29, 2019. New COPs for hospitals are applicable to acute care hospitals, long-term care hospitals (LTCHs), inpatient rehabilitation facilities (IRFs), inpatient psychiatric facilities, children's hospitals, cancer hospitals, and critical access hospitals (CAHs).

These new COPs generally require the discharge planning process to include:

  • Focus on patients' goals of care and treatment preferences

  • Assistance to patients, their families and representatives to select post-acute care (PAC) services providers or suppliers by using and sharing PAC data on quality measure and resource use measures that is relevant and applicable to patients' goals of care and treatment preferences

  • Transfer and referrals of patients along with necessary medical information at the time of discharge to appropriate PAC services providers and suppliers, facilities, and agencies and to other patient service providers and practitioners responsible for patients' follow-up or ancillary care

  • Compliance with requests made by receiving facilities or health care practitioners for additional clinical information necessary for treatment of patients

  • Sending necessary medical information to receiving facilities or appropriate PAC providers and practitioners responsible for patients' follow up care after patients are discharged from hospitals or transferred to other PACs or, for HHAs, other HHAs

  • Hospitals ensuring and supporting patients' rights to access their medical records in the form and format requested by patients, if information is readily producible in such form and format, including in electronic form or format when medical records are maintained electronically

A potential game changer is the requirement to use quality and resource use measures relevant and applicable to patients' goals of care and treatment preferences in the discharge planning process. PAC providers have complained for years that hospital discharge planners/case managers "play favorites" by referring patients to PAC providers that they prefer for a variety of reasons that may be unrelated to quality of care. New requirements to share quality data as part of the discharge planning may help patients make choices and disrupt historic patterns of referrals.

©2019 Elizabeth E. Hogue, Esq. All rights reserved.

The highlighted areas in red make it absolutely clear that anyone involved in the Medicare program must now abide by this rule. It also makes clear that the following reasons for referring to a particular PAC will no longer be accepted under the new rules:

1. I like them

2. They bring us gifts and food

3. They're my friend

4. We have a great relationship

5. We've always referred to them

6. We're not interested in adding new providers

7. They're always here anyway

Unless accompanied by real world outcome and quality data, the above "reasons" for referring are invalid. Any rep or agency who has built their census based upon any of the above reasons should immediately reevaluate their approach and begin selling their programs, services, and quality professionally. Quite simply, the days of "relationship building" as an effective strategy for gaining referrals is now completely over. If you're already on the right side of this equation, you should begin to introduce conversations about the new COPs immediately so as to alert hospital discharge planners about the changes, should they not already be aware of them.

We'll be introducing our selling methodology around these new COPs in our next Home Care Marketing Accelerator 10 week webinar program beginning October 9th. Agencies who are not prepared to sell in this new environment are strongly encouraged to attend. Registration and information on the program are here.

If your agency or reps need one on one guidance on navigating these uncharted referral waters, please contact me for one on one coaching or consulting. You can reach me at 833-POWER31 or simply reply to this email.

Good Selling!

Michael Giudicissi

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