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CoP Educational Series Part 9: Skilled Professional Services Home Health Aide Services

Posted on Thursday, July 13, 2017 8:23 PM

Changes and additions to Skilled Professional Services 484.75 and Home Health Aide Services 484.80 will be outlined in this post.

CoP 484.75 Skilled Professional Services combines and revises the previous 484.30 Skilled Nursing Services, 484.32 Therapy Services and 484.34 Medical Social Services into one CoP.  The newly revised CoP now includes the following skilled professional services – skilled nursing services, physical therapy services, speech-language pathology services, occupational therapy services, physician services and medical social worker services.  Any skilled professionals that provide the identified skilled services directly to patient on behalf of the home health agency, under a contract arrangement or other arrangement, must also participate in the coordination of care.

Skilled professional services are authorized and delivered, as well as supervised by healthcare professionals that meet the appropriate qualifications and who practice in accordance with the home health agency’s policies and procedures. With the revision of the CoPs, rather than focus on discipline specific tasks, broad expectations for all skilled professionals are outlined.

Skilled professionals must assume responsibility for, but not limited to the following:

  • Ongoing interdisciplinary assessment of the patient
  • Development and evaluation of the patient-specific plan of care in partnership with the patient and the patient representative, if there is any.
  • Providing services as order by the physician as indicated in the plan of care
  • Patient, caregiver and family counseling
  • Patient and caregiver education
  • Preparing clinical notes
  • Communication with the physician who is responsible for the home health plan of care and other health care practitioners (as appropriate) related to the current plan of care
  • Participation in the home health agency QAPI program
  • Participation in agency sponsored in-service training


The supervision of skilled professionals is based on discipline.  Nursing is supervised by registered nurses that meet the requirements. RNs oversee LPNs/LVNs.   Rehabilitative therapy services are overseen by either an Occupational or Physical therapist that meet the requirements. All medical social services are supervised by a Social Worker that meets all outlined requirements. The requirements for personnel is outlined in CoP 484.115.

Condition 484.80 Home Health Aide Services states that all home health aide services must be provided by individuals that meet the following qualifications. The individual must have successfully completed a training and competency evaluation program that is approved by the respective state as meeting all requirements and listed in good standing in the state nurse registry.

A home health aide or nurse aide will not be considered completed in a program if there has been a continuous 24 months or greater period-of-time where the described aide services have not been provided.  For lapses of this time-period or greater, the individual must complete another training and competency program prior to delivering any services.

The home health aide training program must include both classroom training, as well as supervised practical training in a setting where the individual demonstrates their knowledge and skills while caring for a patient under the direct supervision of a registered nurse or licensed practical nurse.  Classroom and practical training must include 75 hours.  16-hours of classroom training must precede a minimum of 16-hours of supervised practicum training as part of the 75 hours. A home health aide training program must address each of the following:

  • Communication skills – the ability to read, write and verbally report clinical information to patients, patient representatives and caregivers, as well as to agency staff
  • Observation, reporting and documentation of the patient status and care provided
  • Reading and recording vital signs – specifically temperature, pulse and respirations
  • Basic infection prevention and control procedures
  • Basic elements of body functioning and changes in body functions that must be reported to the aide’s supervisor
  • Maintenance of a clean, safe and healthy environment
  • Recognizing emergencies and the knowledge to institute emergency procedures
  • The physical, emotional and developmental needs of and the way to work with the populations served by the home health agency, including the need to respect the patient, their property and privacy
  • Appropriate and safe techniques for completing personal hygiene and grooming tasks that include bed bath, sponge bath, tub and/or shower bath. Also included is hair shampooing in the sink, the tub and the bed if applicable.
  • Nail and skin care, oral hygiene, toileting and elimination, safe transfer techniques and ambulation, normal range of motion and positioning, recognizing and reporting skin changes and any other task the home health agency may require the aide perform as permitted under state law.

The home health agency is responsible for training the individuals on any skills not listed in the basic checklist that they may ask the aide to complete. The agency must also maintain documentation that demonstrates the requirements of this standard have been met.

A home health aide may provide services on behalf of the home health agency only after the individual has successfully completed a competency evaluation program.  Certain competencies must be evaluated by observing the aide’s performance of the task on a patient while others can be evaluated administering written or oral examinations or, after observation of the individual with a patient. The competency evaluation must be performed by a registered nurse in consultation with other skilled professionals as needed. An individual or aide is not considered competent in any skill or task rated as unsatisfactory. The aide may not complete that task without direct supervision until after receiving additional training and subsequently completing the task satisfactorily on subsequent evaluation. The aide is not considered to have successfully completed the competency evaluation if an unsatisfactory rating is identified in any of the required tasks.

As previously required, home health aides must receive 12 clock hours of in-service training annually during a 12-month period. The training in-service may also occur when the aide is delivering care to a patient. For classroom in-service training, the training must be provided by a registered nurse who possess a minimum of 2 years of nursing experience with 1 year of the experience being in home health. 

Any home health agency may provide a training and competency evaluation program for aides unless within the previous 2 years met one of the listed conditions in the previous standard describing the exceptions. One new item has been added to this list that states any agency that has been excluded from participating in federal health care programs or debarred from participating in any government program can’t provide an aide training and competency evaluation program.

Home health aides are assigned to specific patients by a registered nurse or other appropriate skilled professionals, with written patient care instructions for a home health aide prepared by the appropriate skilled professional or the registered nurse.   Home health aides must be members of the interdisciplinary team, must report changes in the patient’s condition and document accordingly as outlined in the agency policies and procedures.

If a home health aide is providing services to a patient that is also receiving skilled nursing or rehabilitative services, a registered nurse or other appropriate skilled professional who is familiar with the patient, the patient’s plan of care and the written care instruction is required to make a supervisory visit to the patient’s home no less than every 14 days. The aide does not have to be in attendance when the visit is made.  The registered nurse or other appropriate skilled professional must make an annual on-site visit to the location where a patient is receiving care, to observe and assess the aide while the aide is delivering care. Aide supervision must ensure the aide is delivering care in a safe and effective manner. 

For individuals only performing Medicaid personal care-aide services under a Medicaid benefit only, are required to meet state qualification requirements and demonstrate competency only in the tasks the individual is required to furnish.

My final post will cover two new CoPs – QAPI and Infection Prevention and Control.

Written by Peggy Patton, Vice President of Education Services

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