Source: Home Health Line
Given an opportunity to provide insights about Medicare regulatory requirements that are burdensome, many in the home health industry pointed to tub baths currently being an aide competency requirement under the revised Home Health Conditions of Participation (CoPs).
The vast majority of home health patients don’t take tub baths, making it difficult to ensure aides meet CMS’ testing requirement, the industry recently pointed out in comments about CMS’ proposed rule, “Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction.”
It also would be “completely inappropriate and unsafe for home health providers to put patients at risk in order to competency aides on bathing techniques,” the Illinois Homecare & Hospice Council said in its comments.
Safety and mobility concerns — such as falls and difficulty getting in and out of the tub — make it challenging for many home health patients to bathe, according to the National Association for Home Care & Hospice (NAHC).
The proposed rule on burden doesn’t address tub baths for home health patients, though it does take several other steps to make the CoPs less burdensome. But several commenters hope CMS will take their suggestions seriously and eliminate the tub bath competency requirement through future rulemaking.
CMS in the revised CoPs provides a list of skills that must be evaluated by observing the aide’s performance carrying out a task with a patient. The list includes appropriate and safe techniques in performing personal hygiene and grooming tasks including sponge, tub and shower baths. The requirement also includes hair shampooing in the sink, tub and bed.
The home health industry has previously expressed grave concerns about CMS’ expectation that aides perform competencies involving tub baths for actual patients. But CMS didn’t take any steps in the final interpretive guidelines to change this expectation [§484.80(c) and §484.80(c)(1); G768].
“In accordance with §484.80(c)(3), a registered nurse, in consultation with other skilled professionals (as appropriate), must observe the [home health] aide candidate perform each of the tasks above in its entirety to confirm the competence of the candidate,” the final interpretive guidelines state.
These tasks must not be simulated. Use of a mannequin is unacceptable.
Agencies and surveyors had for years relied on prior interpretive guidance that agencies could use pseudo patients for aide competency testing .