05.26.2022

Is your Plan of Care compliant?

SimiTree compliance experts offer tips for creating a survey ready POC

  • Which medications is the patient taking? What about the herbal supplements and over-the-counter vitamins she keeps in a shoebox on her kitchen counter?
  • Are there specific nutritional requirements for the patient? Did the physician order a special diet or supplements?
  • Does the patient have a living will? Who holds power of attorney? Is there a DNR?

Clinicians answer scores of questions like these to create an individualized plan of care for each patient, determining everything from the patient’s cognitive status to which throw rugs may need to be removed to make the home safer for recovery.

A lengthy list of more than 20 components must be included in each plan of care under Medicare’s Conditions of Participation (CoPs) – and a home health agency or physician may require additional information to be included.

With so many components to a compliant plan of care, omissions can easily occur, and agencies frequently find themselves cited by surveyors for failing to get the plan of care right.

“The plan of care is always the No. 1 area for survey citations,” said SimiTree Compliance Senior Manager Sheila Salisbury-Sizemore. “And that’s not surprising, with so many areas where it’s possible to make an error.”

She and SimiTree’s other compliance and clinical operations experts work with agencies to boost survey readiness in all areas, including plan of care compliance. They make certain an agency is crafting plans of care that meet all CoPs as well as any additional requirements by the physician or agency.

“Surveyors always make certain an agency is following its own policies as well as Medicare requirements,” Salisbury-Sizemore said. “So surveyors will also check to make certain any agency-specific requirements for the POC are being followed.”

Salisbury-Sizemore speaks from experience as a former Accreditation Commission for Health Care (ACHC) surveyor. SimiTree’s entire compliance team is made up of current or former surveyors.

Survey expertise is one of the reasons SimiTree’s mock surveys are so popular among both home health and hospice agencies across the nation.

Offered on-site or remotely, mock surveys identify potential citations using the Medicare State Operations Manual in the same manner as a surveyor. Findings are presented, then followed up with extensive survey readiness guidance. SimiTree compliance experts also work with the organization to develop and implement a corrective work plan to make sustainable improvements.

Elements of POC compliance

A compliant plan of care will address all medical, nursing, rehabilitative, social and discharge planning needs identified in the comprehensive assessment, Salisbury-Sizemore said. It will also include detailed and patient-specific interventions for all primary and secondary diagnoses. If the patient has co-morbidities, a compliant plan of care will show how related factors are being addressed as part of care management.

CoPs compliance requires providing the patient all treatments and services outlined on the plan of care, so it is important to craft it carefully, with consideration for all patient co-morbidities and individual needs, Salisbury-Sizemore said.

On the flip side of that, it is equally important for home health aides and clinicians to follow the plan of care to the letter, not improvising by providing any care or services to the patient which are not included on the POC.

Even small things not specifically outlined on the POC must be called into a supervisory nurse for confirmation, documented and reflected in an updated POC, Salisbury-Sizemore said. Otherwise, the agency may be at risk for a citation for failing to follow the care plan.

Download our new POC Guide

Could your organization use a little help in putting together a compliant POC? Our free clinician’s guide is available as a download. It’s a concise guide to each of Medicare’s requirements for the OC.

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SimiTree helps with survey readiness

SimiTree’s compliance experts can help your organization identify survey vulnerabilities and establish an ongoing culture of survey readiness. Our regulatory team is made up of current, former, and certified surveyors who have the industry knowledge and experience to assist both hospice and home health agencies in implementing new and changing regulations and shoring up survey readiness.

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