Today The Centers for Medicare and Medicaid Services (CMS) released the final rule for the Home Health Conditions of Participation (CoP) Delay. Items that previously had a July 13, 2017 implementation date have been delayed until January 13, 2018. The phase-in date for performance improvement projects has been revised to July 13, 2018 with all other QAPI requirements effective January 13, 2018.

The CoPs remained consistent with the proposed rule, with the following exceptions:

• Implementation date has been revised to January 13, 2018.
• Current Administrators will be "grandfathered" in to the personnel requirement. These Administrators will not have to meet the new education and training requirements. The new personnel requirements will have to be met by all Administrators starting employment on or after January 13, 2018.

Interpretive Guidelines

CMS intends to publish a final version of the Interpretive Guidelines in December 2017. Because of this delay in releasing the interpretive guidelines, CMS explained that they expect flexibility by surveyors reviewing compliance.

If you have any questions about the new CoPs, you can email CMS directly at NewHHACoPs@cms.hhs.gov