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Moving Forward with CoP Updates: A 5-Point Checklist

    The new Medicare Conditions of Participation (CoPs) took effect last January 13, 2018, and we expect it to be just the first of many changes geared towards improving quality of care and protecting the rights of beneficiaries. The new rules will greatly impact home health agencies, requiring a patient-centered care coordination, effective communication and better quality assessments to holistically elevate the care delivery system.

    Your CoP implementation plan requires a lot of things to be reviewed, and overseeing all the changes can be an overwhelming task. We have prepared a checklist to keep you on track with your CoP implementation.


    Staffing and organizational structure

    You might need to organize a compliance committee or assign a compliance leader to spearhead the changes within your organization.

    Job descriptions, staff duties and recruitment qualifications may also need to be revisited. Update them as necessary, to incorporate new roles and responsibilities required in your CoP implementation efforts.

    Changes in your EMR

    Your EMR provider plays a significant role in your overall workflow and in your transition to implementing the new CoPs. Check with your EMR provider for updates and changes supporting the new CoPs. They usually provide resources to guide you with new changes applied in their software processes to help you modify your in-house documentation workflow accordingly.

     Quality assessment efforts

    The new CoPs urge agencies to implement a more data-driven approach throughout its processes with the goal of enhancing patient care. You need to revisit your workflows and protocols using reliable tracking indicators to identify areas of improvement. Take advantage of useful reports and analytics from your service providers. You should also include your clinical service providers in the quality assessment efforts to maintain a more successful collaboration supporting the new CoPs.


    Based on your quality assessment results, make a timeframe of what needs to be accomplished. Break big projects down into smaller tasks then prioritize based on urgency and importance. Specify time schedules and deadlines for things to get done. Be sure to make your timeframe open and visible to your entire organization to keep everyone on track on the progress and to create a culture of involvement for everyone.

     Staff engagement

    Implementing the new CoPs is an agency-wide concern that needs active contribution from each person in your organization. It is crucial to get your staff’s full engagement in these efforts as improvements should come from all sides of  your agency.  Explain each person’s role in the success of your endeavor and what’s in it for them. Share your vision and goals to everyone and reveal what changes they should expect and why these changes need to happen.


    A  full, in-depth understanding of  the new rulings and CMS’s ultimate goals in updating the CoPs are essential. Read and discuss with your team the Conditions of Participation Final Rule and the draft of the interpretive guidelines which CMS released last October 27, 2017. You might also look out for updates and other related resources about the CoP before the CMS releases the final guidelines soon.


    Keep up with the new CoP with Qavalo

    Sustain your quality assessment efforts by staying on top of your clinicians’ performance. At Qavalo, our documentation solutions provide you with reporting tools to support your CoP implementation.

    Let’s talk about your specific needs and explore how you can take advantage of the key offerings from Qavalo’s QA outsourcing services. Email us at or give us a call at 916.282.9868.