New Opportunity to Comment on the Burden Estimates for the Proposed HHCoPs
May 12, 2015 02:42 PM
The Centers for Medicare & Medicaid Services (CMS) has announced an opportunity for the public to comment on CMS’ intention to collect information related to the proposed rule for the Home Health Conditions of Participation (HHCoPs). Under the Paperwork Reduction Act (PRA), federal agencies are required to publish notice in the Federal Registerconcerning each proposed collection of information and to allow 60 days for public comment on the proposed action.
Interested persons are invited to send comments regarding CMS’ burden estimates or any other aspect of this collection of information, including any of the following subjects: (1) The necessity and utility of the proposed information collection for the proper performance of the agency’s functions; (2) the accuracy of the estimated burden; (3) ways to enhance the quality, utility, and clarity of the information to be collected; and (4) the use of automated collection techniques or other forms of information technology to minimize the information collection burden.
The notice is standard procedure for the proposed rule making process and does not impact when the final rule for HHCoPs will be published. However, the notice provides another opportunity for public comment on the CMS burden estimates associated with implementing the HHCoPs as proposed. Although the National Association for Home Care & Hospice (NAHC) addressed the overall burden associated with implementing the proposed HHCoPs in its comments on the proposed rule, we will take this opportunity to again address the CMS burden estimates.
NAHC believes CMS has underestimated the burden, both in time and cost, that it will take agencies to meet the proposed HHCoPs. For example, under §484.50 Patient Rights, CMS presumes the burden for complying with revised requirement would fall largely on new non-accredited agencies and significantly underestimates the time it will take existing agencies to comply with standard.
“….patient rights standards and patient notification requirements of the national accrediting organizations would meet or exceed those proposed in this rule; therefore this rule would not impose a burden upon those new HHAs that choose to obtain accreditation status for Medicare deeming purposes. We estimate that it would take 8 hours for each new non-accredited HHA to develop the form In addition we estimate that it would take each existing HHA 1 hour to update its existing patient rights form.”
NAHC encourages all agencies to review the PRA packetand submit comments. NAHC is also interested in hearing from providers regarding their estimate of the time and cost burden for implementing the proposed HHCoPs.
Comments must be received by June 23, 2015.