Staffing flexibility is a specific feature of CMS’s home-health rule, not simply a promise to cut paperwork. The January 13, 2017 final text permits clinical managers drawn from a wider professional list than the October 2014 proposal. This January 15 weekend analysis concerns that Friday publication and its conditions for agencies participating in Medicare and Medicaid. [2017-00283][2014-23895]

The proposal would have assigned the role to a qualified licensed physician or registered nurse. The final list also includes physical therapists, speech-language pathologists, occupational therapists, audiologists and social workers. That expands the eligible professional categories; it does not remove qualifications or establish that an agency’s recruitment costs fell. The two documents record successive choices in one CMS proceeding. [2017-00283][2014-23895]

The operational duties remain substantial. Clinical managers oversee patient services and personnel, coordinate care and referrals, and assure continuing assessment and individualized care-plan updates. Agencies also retain overall responsibility for services provided under arrangement. In incentive terms, greater choice over the staffing arrangement comes with a defined responsibility for what that arrangement must accomplish, rather than permission to abandon care standards. [2017-00283]

CMS scheduled July 13, 2017 general effectiveness and January 13, 2018 commencement of performance-improvement projects. Its stated objectives combine interdisciplinary care with procedural flexibility. The economically useful distinction is between a broader permitted staffing pool and a demonstrated productivity gain. The rule supplies the former; it does not measure the latter or prove that patients received better care as a result. [2017-00283]

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