On October 8, 2014, CMS announced two initiatives with the objective of improving the quality of post-acute care.  Important to home health providers, CMS released a proposed rule that would revise the conditions of participation ("proposed COPs") that regulate home health agencies.

The proposed COPs contain over 200 pages of revised commentary and regulations.  While it is too early to comment with any specificity, it would seem the stage is set for major industry reform.  As CMS has recently suggested, the proposed COPs focus on quality and outcome-driven measures.  Some of the changes are merely updating old concepts, adding some detail and slightly altering content.  Other changes are more expansive, modifying the form and substance of the COPs and, at times, removing and replacing them altogether. For instance, the group of professional personnel standard and annual program review are eliminated and replaced with a quality assessment and performance improvement ("QAPI") standard.