If you thought the only CoPs that CMS was updating recently were just the Emergency Preparedness rule, you were sadly mistaken.  In January CMS released a complete revamp of the Home Health Agency CoPs.  If you are looking for a good analysis of those CoPs, I encourage you to read the summary article by the National Association for Home Care & Hospice (NAHC).   The question some of you may have is how will this affect my implementation for the Emergency Preparedness Rule.  The short answer is it really doesn’t change anything.

The new HHA CoPs have an effective date of July 13, 2017, but the Emergency Preparedness CoPs went into effect on November 16, 2016, with all implementation to be completed by November 16, 2017.  CMS is still instructing agencies to adhere to the original timeline.  Regardless we are still waiting on Interpretive Guidelines for both the Emergency Preparedness Rule and the Home Health Agencies CoPs.  The Emergency Preparedness Rule Interpretive Guidelines are still slotted for a ‘Spring’ release and according to some industry experts, while the HHA Interpretive Guidelines did not even get put into the workflow until sometime this winter.

Ok, I may have fibbed earlier, there is actually one minor change.  When CMS published the Emergency Preparedness Rule in November the Home Health CoP resided at § 484.22, it will now reside at § 484.102, however, the content is the same as what was published in November.  Regardless of location or what the effective date may be, organizations should be in action preparing for compliance.  If you are curious where to start without Interpretive Guidelines, you should check out our recent blog post aptly titled ‘What to do without Interpretive Guidelines?


Crisis Focus, LLC has focused expertise in healthcare emergency management, including CMS compliance. Please visit Crisis Focus’ CMS Emergency Preparedness resource page or contact us for more information.