February 25, 2025 • 18 mins
The episode examines the top 10 home health survey deficiencies of 2024, underscoring the importance of compliance and effective care planning. Jennifer and Kim provide actionable strategies for home health agencies to enhance their survey readiness and improve quality care.
• Identifying and understanding the top 10 deficiencies for compliance
• Importance of comprehensive assessments in care planning
• Challenges faced in interdisciplinary care coordination
• Significance of infection prevention during home health visits
• Technical requirements regarding patient rights documentation
• Strategies for ongoing survey readiness and case management best practices
• Utilizing CHAP resources for enhanced compliance strategies
• Importance of ongoing education and staff training in home health settings
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:00):
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 forour CHAPcast with my co-host,
and that would be Kim Skihan.
Good to have you back, Kim.
Speaker 2 (00:17):
Thanks, jen, good to be here.
Speaker 1 (00:19):
All right.
So today, kim, we're going totalk about, if I'm not mistaken,
the top 10 survey deficienciesfor home health in 2024.
And you know, I know, it'sreally tough for home health
providers.
You know they got all of the,you know budget cuts and
(00:39):
managing with.
You know future cuts and oh, bythe way, you've got to stay
compliant and survey ready atany given time.
So I you know future cuts andoh, by the way, you've got to
stay compliant and survey readyat any given time.
So you know, I feel for them.
I feel that they're under atremendous amount of strain, but
you know they still, asorganizations, need to maintain
their quality, need to maintaintheir compliance, which means
(01:02):
that, optimally, when you have asurvey, you only have standard
deficiencies or as fewdeficiencies as possible.
So you know, can we jump in tofigure out what we're going to
talk about today in terms ofhome health survey deficiencies?
Speaker 2 (01:22):
Sure, absolutely, and this is an area, as you know,
certainly near and dear to myheart, but also to CHAP, because
we do take survey andcompliance seriously, but mostly
as a learning experience forproviders.
As you said, providers arechallenged with day-to-day
(01:44):
operations and compliance and somany other.
You know issues that are goingon, but compliance with
regulation is something thatshould remain top of mind and
ongoing, and one of theresources and that's what we're
going to talk about today is ourCHAP Top 10 Home Health
(02:05):
Deficiencies, which I do want tothank our CHAP Center for
Excellence for compiling thisinformation and making it
available to providers on ourwebsite at chapincorg, under
Resources and Survey Readiness.
It's important to be able tosee what the top 10 deficiencies
(02:26):
are, which means the mostcommonly cited for home health
agencies.
This list is specific to CHAP,but it does correlate in many
ways with what we had seenpreviously, with CMS's top
findings as well, and these arestandards.
When you look at them, they docorrelate with several G-tags,
(02:50):
which are again the CMS COPs andstandards, so it does work to
an advantage for a home healthagency to really stay on top of
what those top areas are.
Speaker 1 (03:07):
Yeah, absolutely.
You know.
I think it's just wonderfulthat we're able to present every
year this list of top 10deficiencies, because I feel
like an organization.
Yes, you need to be trackingand trending what your own
deficiencies are, but you needto see how you're swimming in a
(03:27):
different or a larger pool, ifit were, or you know, as an
example.
So it's a great way tobenchmark yourself.
Plug into other data sourcesthat maybe you have another
benchmarking pool where you canuse that as well.
We feel like the more data thatyou have, the better you can
(03:53):
attack your performanceimprovement issues.
So I'm really proud that CHAPdoes compile this on an annual
basis and put it out.
Speaker 2 (04:06):
Absolutely, and as a value add there are tips for
compliance.
So it really is a greatresource, you know, for folks to
have as well.
Jennifer, in looking at the top10 for home health, we do
notice that, again, many of thetop 10 findings are related to
the care planning andcomprehensive assessment.
Do you have insight or thoughtsas to why this is I'm going to
(04:30):
call it a perennial favorite interms of the findings that just
keep you know coming up, bothfor us as well as for CMS?
Speaker 1 (04:40):
Well, that's a great question and I'll start and I'm
going to pitch it back to youbecause you're the home health
expert here and I have some orclinicians rather think of this
as it's a piece of paper.
(05:08):
It's a document I have tomaintain because this regulation
says so.
They're not really using it forwhat it is intended to be used
as meaning, as this is theroadmap or this is the guide to
providing care.
So if, kim, you were a MrsFiddlebottom's nurse and you had
(05:30):
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 carein order to really pick up and
provide seamless care for thatpatient, in whatever setting
(05:50):
they're receiving their care.
So it's more than a document.
It's driven by the assessmentprocess, which I know OASIS is
long and it can be timely andall of that.
But all of that is reallyimportant getting all of that
(06:11):
data in there in order to buildthe best individualized plan of
care for that patient aspossible.
So now I'm going to pitch itback to you and I want to hear
your thoughts about careplanning and assessment.
Speaker 2 (06:24):
Well, absolutely, I think everything you said is
spot on the key with careplanning.
The bigger challenge I see withhome health versus hospice is
that hospice has embedded in theregulations the requirement for
interdisciplinary group right,the absolute requirement for IDG
(06:47):
to be part of care planning anddiscussion.
There was still theresponsibility of the RN to make
sure that the care plan isimplemented and a case
management component to it.
But in home health, while theCOPs, especially the revised
COPs remember we had the change,the update this past year, you
(07:07):
know 2024 was a banner year forhome health with the revised
COPs, you know more expresslydescribing the interdisciplinary
team, if you will, but therestill is not that mandate that
is in place.
As far as frequency of meetingsand communication In home
health, when you have especiallydifferent disciplines or, to
(07:30):
your point, handoffs, you know,between even you know, nurses,
if you will, there needs to bethat oversight and communication
and coordination to make surethat the care plan is reflective
of all of the patient's needs,the patient's needs and the
(07:51):
coordination of care andservices, to make sure that any
changes in status are addressedin a timely manner and that the
team is aware.
And that, to me, is the biggestchallenge with home health.
The individualization of careplans is always an issue, mostly
because of when organizationsare not optimizing their EMR
(08:17):
usually their electronic medicalrecord and really putting in
additional information to makethe care plan specific to a
patient, that sometimes that canbecome an issue.
And then connecting the dotsbetween the assessments, both
initially and ongoing, and thecare plan and making sure that
(08:43):
care, treatment and services isbeing implemented.
It's a challenge.
Speaker 1 (08:47):
It is a challenge and I agree to all these Check,
check, check challenge and Iagree to all these check, check
check.
So let's connect some more dots.
When you look at CHAP's top 10,deficiencies.
Speaker 2 (09:03):
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 ofthose findings are related to
home visits hand hygiene, a bagtechnique, et cetera.
So when organizations arepreparing and conducting mock
(09:27):
surveys, really in-homeobservation is key to that.
To observe that requirement,home health aides, providing
services as included on theircare plan, again seems to be a
(09:48):
perennial topic as well.
I know I can see you pursingyour lips.
Speaker 1 (09:54):
Can you.
Speaker 2 (09:55):
Yes, I can, jennifer and I have had a long, long
history of conversation aboutAIDS being any AIDS services,
AIDS documentation, AIDSsupervision being on the top 10.
We really would like for everyhome health agency and every
(10:17):
provider to make a concertedeffort to get this off of the
top 10.
Yeah, let's make that the goal.
Yeah, the other thing is andthis is something that actually
is a little bit surprising forme, especially when I look again
, again at the new you know thechanges in the standards, but
the language in the standardshasn't changed.
(10:39):
So the technical requirementsof the patient rights document,
what needs to be included, aswell as the written information
that needs to be provided to thepatient.
That requirement has been inplace since 2018, when the COPs
were first revised, and itcontinues to remain a top.
(11:00):
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 thatorganizations really need to
make sure that they put those inplace.
Um, you know, across the board.
Speaker 1 (11:21):
Yeah, All of that is extremely important, you know,
and it's it's part of beingsurvey ready really at any given
time.
So we know that providers aregoing to have deficiencies and,
um, what can we tell ourproviders out there about
strategies that they can utilizeor put into place to help
(11:44):
improve some of those thingswe're seeing on the top 10, but
also, you know, being overallsurvey ready.
Speaker 2 (12:04):
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 thatorganizations have ongoing
survey readiness processes, notjust when they are ready, think
they're in the window or sixmonths from their survey,
because, as we know, complaintsurveys can happen at any time
and with changes in staff andmanagement there are always, you
(12:25):
know, opportunities to remindstaff and also have them more
comfortable with the surveyprocess.
So that needs to include all ofthe aspects that are in
Appendix B that really doprovide an outline when you look
at information gathering andthe beginning of Appendix B,
great outline on how to conducta mock survey so that you can
(12:49):
monitor those areas ongoing andmake sure that opportunities
identified are incorporated intoyour QAPI program are
incorporated into your QAPIprogram.
The other topic that, aslooking at this as so many years
(13:10):
with assessment and careplanning as top deficiencies and
what we see in the field, itreally is important for
organizations to make sure thatthe RNs and the therapists for
therapy-only cases do understandthe principles of case
management and their role as acase manager, that formal
(13:35):
structure required, if you willdesignated, you know, idg
component, even though they are,you are required to have an
interdisciplinary coordinationand team involvement.
It's really important becausethe clinicians who are coming
into home health many are comingwithout prior home health or
(13:57):
case management experience ifthey're coming from a facility
or a role that involves shiftwork.
And when we're outside of bricksand mortar, you really are
relying on the eyes and ears ofall the people the clinicians
and the aides who are in thehome to work together to make
(14:19):
sure, in conjunction with thephysician, that all the
patient's needs are being metand that any identified issues
assessed are incorporated intothe care plan.
And that's a skill that needsto be developed with the staff,
because not all RNs and not alltherapists are case managers.
(14:41):
They can perform the skills youknow and may conduct care,
treatment and services orperform them, but they may not
be able to effectively casemanage.
So that brought me to think.
That got me to thinking thatthis would be.
I think this would be anexcellent topic for a future
(15:02):
chap cast to really discuss inmore detail the principles of
case management and the role ofthe case manager.
What do you think, jessica?
Speaker 1 (15:12):
Yeah, I absolutely agree.
I think there should be casemanagement university.
Agree, I think there should becase management university.
When you come to the home-basedcare setting, you have to go to
case management or caremanagement 101, right, because
you know, organizations orientnurses and therapists different
(15:35):
ways to how to be a care manager.
So there should be somestandardization 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.
Speaker 2 (15:50):
Sounds good.
Speaker 1 (15:51):
All right, Kim, your number one takeaway from today.
Speaker 2 (15:56):
Ongoing survey readiness, using the data that
we provide, as well as othersource data that an organization
may have with our top 10deficiencies, your own agency's
previous survey history andmaking sure that you have that
ongoing proactive surveyreadiness program to be able to
(16:22):
make sure that you are incompliance with the conditions
of participation and thestandards well in advance of an
unannounced survey.
Speaker 1 (16:31):
Yep, totally agree with that and I would say do not
be afraid to sashay your waythrough Appendix B, because the
interpretive guidelines are agift from CMS and basically say
what is going to happen in asurvey and what is going to be
looked for.
So sashay away, as it were said, through that Appendix B.
(16:54):
Any other parting thoughts, kim?
Speaker 2 (17:03):
be Any other parting thoughts, kim.
No, I think that you know, justgo forth and continue to
conquer and, you know, do thegreat work that you, as home
health providers, are doing outthere and just make a difference
every day with your patients'lives, day with your patients'
lives Excellent.
Speaker 1 (17:17):
That's great takeaway thoughts and be sure you can
look at on the webpage for CHAP.
We have a number of differentresources available not just our
top 10, that can help you be amore successful and quality
provider.
So with that, we're going tosign off for today.
(17:38):
Provider.
So with that, we're going tosign off for today.
Thanks for all you out theretaking time to plug into our
podcast today From Kim, me andthe entire CHAP staff.
Keep your quality needlessurging forward, stay safe and
well, and thanks for all you do.
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 forour CHAPcast with my co-host,
and that would be Kim Skihan.
Good to have you back, Kim.
Speaker 2 (00:17):
Thanks, jen, good to be here.
Speaker 1 (00:19):
All right.
So today, kim, we're going totalk about, if I'm not mistaken,
the top 10 survey deficienciesfor home health in 2024.
And you know, I know, it'sreally tough for home health
providers.
You know they got all of the,you know budget cuts and
(00:39):
managing with.
You know future cuts and oh, bythe way, you've got to stay
compliant and survey ready atany given time.
So I you know future cuts andoh, by the way, you've got to
stay compliant and survey readyat any given time.
So you know, I feel for them.
I feel that they're under atremendous amount of strain, but
you know they still, asorganizations, need to maintain
their quality, need to maintaintheir compliance, which means
(01:02):
that, optimally, when you have asurvey, you only have standard
deficiencies or as fewdeficiencies as possible.
So you know, can we jump in tofigure out what we're going to
talk about today in terms ofhome health survey deficiencies?
Speaker 2 (01:22):
Sure, absolutely, and this is an area, as you know,
certainly near and dear to myheart, but also to CHAP, because
we do take survey andcompliance seriously, but mostly
as a learning experience forproviders.
As you said, providers arechallenged with day-to-day
(01:44):
operations and compliance and somany other.
You know issues that are goingon, but compliance with
regulation is something thatshould remain top of mind and
ongoing, and one of theresources and that's what we're
going to talk about today is ourCHAP Top 10 Home Health
(02:05):
Deficiencies, which I do want tothank our CHAP Center for
Excellence for compiling thisinformation and making it
available to providers on ourwebsite at chapincorg, under
Resources and Survey Readiness.
It's important to be able tosee what the top 10 deficiencies
(02:26):
are, which means the mostcommonly cited for home health
agencies.
This list is specific to CHAP,but it does correlate in many
ways with what we had seenpreviously, with CMS's top
findings as well, and these arestandards.
When you look at them, they docorrelate with several G-tags,
(02:50):
which are again the CMS COPs andstandards, so it does work to
an advantage for a home healthagency to really stay on top of
what those top areas are.
Speaker 1 (03:07):
Yeah, absolutely.
You know.
I think it's just wonderfulthat we're able to present every
year this list of top 10deficiencies, because I feel
like an organization.
Yes, you need to be trackingand trending what your own
deficiencies are, but you needto see how you're swimming in a
(03:27):
different or a larger pool, ifit were, or you know, as an
example.
So it's a great way tobenchmark yourself.
Plug into other data sourcesthat maybe you have another
benchmarking pool where you canuse that as well.
We feel like the more data thatyou have, the better you can
(03:53):
attack your performanceimprovement issues.
So I'm really proud that CHAPdoes compile this on an annual
basis and put it out.
Speaker 2 (04:06):
Absolutely, and as a value add there are tips for
compliance.
So it really is a greatresource, you know, for folks to
have as well.
Jennifer, in looking at the top10 for home health, we do
notice that, again, many of thetop 10 findings are related to
the care planning andcomprehensive assessment.
Do you have insight or thoughtsas to why this is I'm going to
(04:30):
call it a perennial favorite interms of the findings that just
keep you know coming up, bothfor us as well as for CMS?
Speaker 1 (04:40):
Well, that's a great question and I'll start and I'm
going to pitch it back to youbecause you're the home health
expert here and I have some orclinicians rather think of this
as it's a piece of paper.
(05:08):
It's a document I have tomaintain because this regulation
says so.
They're not really using it forwhat it is intended to be used
as meaning, as this is theroadmap or this is the guide to
providing care.
So if, kim, you were a MrsFiddlebottom's nurse and you had
(05:30):
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 carein order to really pick up and
provide seamless care for thatpatient, in whatever setting
(05:50):
they're receiving their care.
So it's more than a document.
It's driven by the assessmentprocess, which I know OASIS is
long and it can be timely andall of that.
But all of that is reallyimportant getting all of that
(06:11):
data in there in order to buildthe best individualized plan of
care for that patient aspossible.
So now I'm going to pitch itback to you and I want to hear
your thoughts about careplanning and assessment.
Speaker 2 (06:24):
Well, absolutely, I think everything you said is
spot on the key with careplanning.
The bigger challenge I see withhome health versus hospice is
that hospice has embedded in theregulations the requirement for
interdisciplinary group right,the absolute requirement for IDG
(06:47):
to be part of care planning anddiscussion.
There was still theresponsibility of the RN to make
sure that the care plan isimplemented and a case
management component to it.
But in home health, while theCOPs, especially the revised
COPs remember we had the change,the update this past year, you
(07:07):
know 2024 was a banner year forhome health with the revised
COPs, you know more expresslydescribing the interdisciplinary
team, if you will, but therestill is not that mandate that
is in place.
As far as frequency of meetingsand communication In home
health, when you have especiallydifferent disciplines or, to
(07:30):
your point, handoffs, you know,between even you know, nurses,
if you will, there needs to bethat oversight and communication
and coordination to make surethat the care plan is reflective
of all of the patient's needs,the patient's needs and the
(07:51):
coordination of care andservices, to make sure that any
changes in status are addressedin a timely manner and that the
team is aware.
And that, to me, is the biggestchallenge with home health.
The individualization of careplans is always an issue, mostly
because of when organizationsare not optimizing their EMR
(08:17):
usually their electronic medicalrecord and really putting in
additional information to makethe care plan specific to a
patient, that sometimes that canbecome an issue.
And then connecting the dotsbetween the assessments, both
initially and ongoing, and thecare plan and making sure that
(08:43):
care, treatment and services isbeing implemented.
It's a challenge.
Speaker 1 (08:47):
It is a challenge and I agree to all these Check,
check, check challenge and Iagree to all these check, check
check.
So let's connect some more dots.
When you look at CHAP's top 10,deficiencies.
Speaker 2 (09:03):
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 ofthose findings are related to
home visits hand hygiene, a bagtechnique, et cetera.
So when organizations arepreparing and conducting mock
(09:27):
surveys, really in-homeobservation is key to that.
To observe that requirement,home health aides, providing
services as included on theircare plan, again seems to be a
(09:48):
perennial topic as well.
I know I can see you pursingyour lips.
Speaker 1 (09:54):
Can you.
Speaker 2 (09:55):
Yes, I can, jennifer and I have had a long, long
history of conversation aboutAIDS being any AIDS services,
AIDS documentation, AIDSsupervision being on the top 10.
We really would like for everyhome health agency and every
(10:17):
provider to make a concertedeffort to get this off of the
top 10.
Yeah, let's make that the goal.
Yeah, the other thing is andthis is something that actually
is a little bit surprising forme, especially when I look again
, again at the new you know thechanges in the standards, but
the language in the standardshasn't changed.
(10:39):
So the technical requirementsof the patient rights document,
what needs to be included, aswell as the written information
that needs to be provided to thepatient.
That requirement has been inplace since 2018, when the COPs
were first revised, and itcontinues to remain a top.
(11:00):
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 thatorganizations really need to
make sure that they put those inplace.
Um, you know, across the board.
Speaker 1 (11:21):
Yeah, All of that is extremely important, you know,
and it's it's part of beingsurvey ready really at any given
time.
So we know that providers aregoing to have deficiencies and,
um, what can we tell ourproviders out there about
strategies that they can utilizeor put into place to help
(11:44):
improve some of those thingswe're seeing on the top 10, but
also, you know, being overallsurvey ready.
Speaker 2 (12:04):
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 thatorganizations have ongoing
survey readiness processes, notjust when they are ready, think
they're in the window or sixmonths from their survey,
because, as we know, complaintsurveys can happen at any time
and with changes in staff andmanagement there are always, you
(12:25):
know, opportunities to remindstaff and also have them more
comfortable with the surveyprocess.
So that needs to include all ofthe aspects that are in
Appendix B that really doprovide an outline when you look
at information gathering andthe beginning of Appendix B,
great outline on how to conducta mock survey so that you can
(12:49):
monitor those areas ongoing andmake sure that opportunities
identified are incorporated intoyour QAPI program are
incorporated into your QAPIprogram.
The other topic that, aslooking at this as so many years
(13:10):
with assessment and careplanning as top deficiencies and
what we see in the field, itreally is important for
organizations to make sure thatthe RNs and the therapists for
therapy-only cases do understandthe principles of case
management and their role as acase manager, that formal
(13:35):
structure required, if you willdesignated, you know, idg
component, even though they are,you are required to have an
interdisciplinary coordinationand team involvement.
It's really important becausethe clinicians who are coming
into home health many are comingwithout prior home health or
(13:57):
case management experience ifthey're coming from a facility
or a role that involves shiftwork.
And when we're outside of bricksand mortar, you really are
relying on the eyes and ears ofall the people the clinicians
and the aides who are in thehome to work together to make
(14:19):
sure, in conjunction with thephysician, that all the
patient's needs are being metand that any identified issues
assessed are incorporated intothe care plan.
And that's a skill that needsto be developed with the staff,
because not all RNs and not alltherapists are case managers.
(14:41):
They can perform the skills youknow and may conduct care,
treatment and services orperform them, but they may not
be able to effectively casemanage.
So that brought me to think.
That got me to thinking thatthis would be.
I think this would be anexcellent topic for a future
(15:02):
chap cast to really discuss inmore detail the principles of
case management and the role ofthe case manager.
What do you think, jessica?
Speaker 1 (15:12):
Yeah, I absolutely agree.
I think there should be casemanagement university.
Agree, I think there should becase management university.
When you come to the home-basedcare setting, you have to go to
case management or caremanagement 101, right, because
you know, organizations orientnurses and therapists different
(15:35):
ways to how to be a care manager.
So there should be somestandardization 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.
Speaker 2 (15:50):
Sounds good.
Speaker 1 (15:51):
All right, Kim, your number one takeaway from today.
Speaker 2 (15:56):
Ongoing survey readiness, using the data that
we provide, as well as othersource data that an organization
may have with our top 10deficiencies, your own agency's
previous survey history andmaking sure that you have that
ongoing proactive surveyreadiness program to be able to
(16:22):
make sure that you are incompliance with the conditions
of participation and thestandards well in advance of an
unannounced survey.
Speaker 1 (16:31):
Yep, totally agree with that and I would say do not
be afraid to sashay your waythrough Appendix B, because the
interpretive guidelines are agift from CMS and basically say
what is going to happen in asurvey and what is going to be
looked for.
So sashay away, as it were said, through that Appendix B.
(16:54):
Any other parting thoughts, kim?
Speaker 2 (17:03):
be Any other parting thoughts, kim.
No, I think that you know, justgo forth and continue to
conquer and, you know, do thegreat work that you, as home
health providers, are doing outthere and just make a difference
every day with your patients'lives, day with your patients'
lives Excellent.
Speaker 1 (17:17):
That's great takeaway thoughts and be sure you can
look at on the webpage for CHAP.
We have a number of differentresources available not just our
top 10, that can help you be amore successful and quality
provider.
So with that, we're going tosign off for today.
(17:38):
Provider.
So with that, we're going tosign off for today.
Thanks for all you out theretaking time to plug into our
podcast today From Kim, me andthe entire CHAP staff.
Keep your quality needlessurging forward, stay safe and
well, and thanks for all you do.
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