Home Health Blogger

Home Health 2018 CoPs: Updated Personnel Qualifications

Posted by Joy Joan E. De Castro, RN, MSN on Oct 24, 2017

Medicare's new home health Conditions of Participation go into effect in January 2018. There are multiple changes to the language of the condition regarding personnel qualifications §484.105. Changes to the language include the following:

Changes to language at CoP at §484.105, 115

Ensure your job descriptions, staff qualification requirements are aligned with the staff qualifications and job responsibilities listed in the  HH CoP for the following positions:

Occupational Therapist, Sec. 484.115(f):

Home-Health-Job-Descriptions-2018

The occupational therapist (“OT”) must be licensed where the HHA is located if licensure is required. If licensure is not required, the OT must have graduated from an OT program accredited by the Accreditation Council for Occupational Therapy Education (“ACOTE”) of the American Occupational Therapy Association (“AOTA”) or any successor organization of the ACOTE. After completion of the requisite educational requirements, the OT must be eligible for or have taken the OT certification examination administered by the National Board for Certification in Occupational Therapy (“NBCOT”). There are additional requirements for OTs practicing on or before December 31, 1977, January 1, 2008 and December 31, 2009 that HHAs should note as they include varying educational and board certification requirements. There are also additional education and board certification requirements for OTs educated outside of the United States.

Occupational Therapy Assistant, Sec. 484.115(g):

The OT assistant must be licensed where the HHA is located if licensure is required. If licensure is not required, the OT assistant must have graduated from an OT assistant program accredited by the ACOTE of the AOTA or any successor organization of the of the ACOTE. After completion of the requisite educational requirements, the OT assistant must be eligible for or have taken the OT assistant certification examination administered by the NBCOT. There are additional requirements for OT assistants practicing after December 31, 1977 and on or before December 31, 2007, on or before December 31, 2009 and after January 1, 2010. There are also additional education and board certification requirements for OT assistants educated outside of the United States.

Physical Therapist, Sec. 484.115(h)

A physical therapist (“PT”) must be licensed where the HHA is located if licensure is required. If licensure is not required, the PT must have graduated from a PT program approved by The Commission on Accreditation in Physical Therapy Educati14-11-04-CMS.jpgon (“CAPTE”) or any successor organization of the CAPTE. There are additional requirements for PTs practicing before January 1, 1966, on or before December 31, 1977, before January 1, 2008 and on or before December 31, 2009. There are also additional education and board certification requirements for PTs educated outside of the United States.

Physical Therapist Assistant, Sec. 484.115(i)

A PT assistant must be licensed where the HHA is located if licensure is required. If licensure is not required, the PT assistant must have graduated from a PT assistant program approved by CAPTE and have passed a national examination for PT assistants. There are additional requirements for PT assistants practicing on or before December 31, 1977, before January 1, 2008 and on or before December 31, 2009.

Physician, Sec. Sec. 484.115(j)

A physician must meet the Final CoP implemented at Sec. 410.20(b). Please refer to a more detailed discussion in this article pertaining to the physician CoP requirements found at Sec. 410.20.

Registered Nurse, Sec. 484.115(k)

A registered nurse must have graduated from an approved school of nursing and be licensed in the state where practicing.

Social Work Assistant, Sec. 484.115(l)

A social work assistant must have a baccalaureate degree in social work, psychology, sociology or another field related to social work and at least one year of social work experience in a health care setting. A social work assistant may also qualify if he/she has two years of appropriate experience and has a satisfactory grade on a proficiency examination conducted, approved or sponsored by the U.S. Public Health Service. These proficiency determinations do not apply to persons licensed or seeking initial qualifications as a social work assistant after December 31, 1977.

Social Worker, Sec. 484.115(m)

A social worker must have a master’s or doctoral degree from a school of social work accredited by the Council on Social Work Education and one year of social work experience in a health care setting.

Speech-Language Pathologist, Sec. 484.115(m)

A speech-language pathologist must have a master’s or doctoral degree in speech-language pathology and be licensed in the state where practicing. If licensure is not required, the speech-language pathologist must have completed or be in the process of completing 350 clock hours of supervised clinical practice experience. It is also permissible for the speech-language pathologist to have performed not less than nine months of supervised speech-language pathologist services after obtaining a master’s or doctoral degree in speech-language pathology or a related field. Successful completion of a national examination in speech-language pathology is also allowed in states where licensure is not required.

Audiologist, Sec. 484.115(b)

An audiologist must meet the education and experience requirements for a Certificate of Clinical Competence issued by the American Speech-Language-Hearing Association. If the audiologist meets the educational requirements, he/she may still serve as the audiologist provided he/she is in the process of accumulating the supervisory experience required for certification.

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