Continuity of care is more concrete when someone is responsible for keeping a plan current. CMS’s January 13, 2017 home-health rule assigns clinical managers duties that include coordinating referrals, assuring ongoing assessment of patient needs and overseeing individualized care-plan development and updates. This January 15 weekend reflection concerns that earlier publication. [2017-00283]

The October 2014 proposal had identified a managerial role covering personnel and patient services, whether delivered directly or under arrangement. That history helps explain the ethical stake: dividing the work among providers should not make responsibility for the whole plan disappear. The final text retains agency responsibility for arranged services and requires written agreements with the outside providers. [2017-00283][2014-23895]

Responsibility also needs an accurate description of who may hold it. The proposal envisaged a qualified licensed physician or registered nurse. The final list additionally includes physical therapists, speech-language pathologists, occupational therapists, audiologists and social workers. Recognizing that broader professional range avoids confusing a historical staffing proposal with the adopted coordination framework. [2017-00283][2014-23895]

The conditions concern home-health agencies participating in Medicare and Medicaid. General effectiveness was scheduled for July 13, 2017, with performance-improvement projects beginning January 13, 2018. Neither a managerial title nor a written plan establishes that care became more attentive. Proposal and final rule document one institutional response: they make duties visible, while leaving the quality of their execution a separate question rather than a moral achievement already proved. [2017-00283][2014-23895]

Source documents

  1. Medicare and Medicaid Program: Conditions of Participation for Home Health Agencieshttps://www.govinfo.gov/content/pkg/FR-2017-01-13/html/2017-00283.htm
  2. Medicare and Medicaid Program: Conditions of Participation for Home Health Agencieshttps://www.govinfo.gov/content/pkg/FR-2014-10-09/html/2014-23895.htm